Critique of: Impacts of soil carbon sequestration on life cycle greenhouse gas emissions in Midwestern USA beef finishing systems, (2018) by Dr. Paige L. Stanley et al, Michigan State University

Canadian Cattlemen beef photo

Credit: Canadian Cattlemen

A number of recent research reports/reviews have concluded that, contrary to popular opinion, intensive feed-lot systems for finishing beef cattle result in lower greenhouse gas emissions per kg of beef carcass weight than grazing (“grass-fed”) systems (an example here). However, a recent paper from a group at Michigan State University found that, when the soil carbon sequestration benefit is included with a well-managed grazing system, the balance is reversed. Because of the dramatic nature of this finding and a long-term personal interest in soil carbon sequestration, I have reviewed their paper in detail. I conclude that their results are not realistic nor supported adequately by their research methodology.

Dr. Stanley et al describe research where beef pasture research fields in Michigan were converted from continuous grazing to managed-rotational grazing. After four years, they reported that the organic carbon (OM) content in the upper 30 cm of soil increased 40% from 34 to 48 tonnes/ha – or an average of 3.6 t/ha/year.

If it is assumed that soil organic matter is 58% carbon, this equates to an average OM addition of 6.2 t/ha/year. And if it’s assumed (generously, 2018 reference here) that about 25% of the organic matter (tops and roots), fixed by the forage crop during the four years after grazing, remains in the soil after the four years, this equates to about 25 t/ha/year of annual organic matter addition. Actual crop organic matter production must have been somewhat larger to account for the material removed and respired by grazing animals.

To put this in perspective, 25t/ha/year is about equivalent to the grain, stover, root and root exudates produced by a 190 bushel/acre corn crop, assuming grain represents 40% of total OM .

I don’t believe that this is credible.

So why the discrepancy? There is no suggestion that the authors fudged their data and no evidence for such, but here are some possible explanations.

Firstly, the authors give no accounting of how the manure produced in the non-grazing season was used – the manure coming from hay apparently purchased from off-station and used to feed cows and over-wintering calves. The authors state that no commercial fertilizer was used in this research so manure likely supplied the fertility need, especially for potassium for alfalfa (not clarified in the research description).  Manure addition would have also provided organic matter.

Secondly the authors measured the organic carbon content in the upper 30cm of soil at both the beginning and end of the four-year period, but apparently made no adjustment for possible changes in soil bulk density (g/cm3 of dry soil). A change in soil weight per volume could have affected the results – though very likely not nearly enough to trigger a 40% increase in measured soil OM.

Third, the authors appear to have only one valid replicate comparison for the change in soil organic matter content. They do present data for three sample locations but only one comparison involves the same soil type measured both before and after (i.e., a “sandy loam” soil).

The paper has some other weaknesses which cause concern. It’s essentially devoid of statistical analysis and most of the calculations are based on data from elsewhere including Michigan averages and global numbers provided by the International Panel on Climate Change or other sources. But yet the authors present their results to three (sometimes four) significant figures, implying unjustified precision. One significant-figure precision would be more appropriate.

In summarizing, this is not an attempt to attack the integrity of researchers or institution, or to understate the importance of the issue under consideration. However, I don’t believe that the results provide more than a hint that soil organic matter might be enhanced by well-managed grazing in a beef system; and this, in turn, could reduce the net greenhouse gas emissions in beef production.

Final note: I did try twice, without success, to contact the senior author before drafting the comments provided above.




What’s Your View on Mandatory Labelling of GM Foods? It depends so much on whether you have ‘Skin In The Game’

This column has two parts: The first discusses why the prospect of mandatory labelling of foods containing GM ingredients is viewed different if you are a farmer. The second is a critique of a research paper by Kolodinski and Lusk on public attitudes to short-term mandatory GM labelling in Vermont. Each is about 1200 words.

GLP Label GM Food

The on-going debate has heated again in North America about mandatory labelling of foods containing genetically modified/genetically engineered ingredients (also known as GM, GE and GMOs; the abbreviation GM will be used mostly in this column). That’s probably because of recent proposals made by the United States Department of Agriculture (USDA) on labelling options – a response to an earlier law mandating such passed by the American government on July 27, 2014.

The federal law was triggered by a similar law passed by the State of Vermont in 2014, becoming effective on July 1, 2016 – and a worry in Washington that other American states would also institute their own state-specific rules for mandatory labelling – effectively creating a nightmare for national food companies forced to comply with a potentially complex mess.

The federal law eliminated the right of states, including Vermont, to pass/implement their own labelling laws – but introduced a series of related debates on how to label, what to label, how to enforce  and more. The federal law gave USDA two years to develop the labelling specifics – and hence the proposals released recently.

That this is occurring at all is the result of a largely successful campaign by organizations opposed to genetically engineering in agriculture who have used a ‘right to know’ theme on labelling as an early step in attempting eliminate most/all genetically modified ingredients from the food system.

This is an approach which has worked very well for them in Europe where the combination of government requirements for mandatory labelling and anti-GM campaigning have essentially eliminated GM ingredients from foods in grocery stores. The one huge exception, of course, involves food products made from/by farm animals which are fed GM-based feeds; there is an inadequate supply of non-GM protein-rich feed available to European livestock farmers. And, despite the best efforts of anti-GM pressure groups, these products remain on grocery shelves – at least for now.

There is broad concern that what worked in Europe could also work in North America, meaning loss of the large benefits which GM have meant – both economic and environmental – for food and fibre production in the United States and Canada. Hence the strong opposition to mandatory labelling among many biotechnology companies, farmers and other biotech supporters in these countries.

While the strongest voices in support of mandatory GM labelling have come from anti-GM groups and commercial entities which will profit from GM-ingredient exclusions, support has also come from some individuals – commonly academics and journalists – generally known to be supportive of the use of GM technology in agriculture.

Their rationale is a belief that if/when mandatory GM labelling does occur, unlike in Europe, most North American consumers will adjust to this quickly; they will learn to ignore words on labels like ‘contains genetically engineered ingredients’ knowing that this has no significance to human health (the exception being ingredients deliberately engineered to improve health). Most of these proponents of mandatory labelling have been clear that their opinions are based not so much on solid research – for there is scarcely any – but rather intuitive feelings about human nature and experience with consumer whims.

To be fair on research, there is plenty of survey data. Jayson Lusk and his colleagues, former at Oklahoma State University, now at Purdue University, have done monthly surveys of consumer attitudes to many things including GM labelling. A late June 2018 survey report from the International Food Information Council Foundation (an industry-funded group) found 47% of Americans avoid foods known to be genetically engineered and, further, that “uncertainty about which foods are genetically modified is the primary reason for not avoiding [GE] foods.”

However, what consumers tell surveyors is often very different from what they do in practice. See, for example, this review by Alexander Stein of the EU Commission, “Acceptance of ‘GM food’ in Europe: What people say and do.”

Stein includes this graphic:


Pro-mandatory-labelling advocates know this discrepancy well, and their position seems more instinctive. If I can generalize, it’s “Other approaches aren’t solving the problem – i.e., lack of broad consumer/support for GM products – so why not try mandatory labels? Let’s give it a shot.”

Very apparent, at least to me, is the fact that virtually none of those professionals advocating labelling actually grows farm crops – GM or not – to provide for family income. Few if any know the ‘joy’ of harvesting corn-borer-damaged, lodged corn or of filling insecticide boxes on planters – or of deciding which herbicide to use on weed escapes in a non-GM crop knowing that every choice is likely to work only partly, or cause crop damage, and will cost hundreds (more likely thousands) of dollars to apply. None of them have kids whose attendance at summer camps depends on protecting crop yields and quality from pest damage, and the cost of doing so.

If mandatory labelling means loss of markets for GM crops as ‘right to know’ proponents intend, the consequences for farmers will be far bigger than an “Oops, guess I was wrong.”

(Yes, I recognize that farmers growing GM-free ‘identity preserved’ crops receive premiums for their efforts, but that was not the case in pre-GM days, nor will it be again if the GM option is withdrawn.)

To use the vernacular, farmers have ‘skin in the game.’ Well-meaning academics and journalists don’t. In my view that makes a big difference.

As one of those farmers, I have no idea whether mandatory GE labelling will work or not. But in the absence of good clear evidence for the former, I need more than “let’s give it a shot.” I also support credible voices who say food labelling should be reserved for meaningful information on health and nutrition – and not the scare tactics of albeit-very-strong voices of the anti-GMO crowd.

Please note that this is not a blanket condemnation of top researchers and quality journalists – but rather a difference in viewpoint on one – albeit very significant – issue.

An additional reason for caution involves the key question of what, actually is a GM or genetically modified/engineered crop, animal or food (or ‘biologically engineered’ to use the USDA’s apparent wording preference)?

Nathanel Johnston addressed this well in his classic, It’s practically impossible to define ‘GMOs’ . Pro-biotech labelling proponents generally have something far less comprehensive in mind than many activists. And a quick check of postings on Twitter shows that the food industry is all over the map on what’s to be in and what’s not.

Anyone who thinks the noise will down once mandatory labelling is in place is naive in my view. It simply shifts from ‘whether’ to ‘what’ – not to mention the real reason for the activists’ campaign: elimination.

Another concern stems from a discussion by Mark Lynas in his great new book, Seeds of Science. He describes how, in earlier days of seeking public assurance of precautions being taken by biotech researchers, technicians allowed themselves to be photographed in attire resembling space suits. Casually dressed photographers a few feet away obligingly conveyed the message to the rest of the world: ‘GMOs must be dangerous if research workers need to dress like that.’

Lynas states, “It was a classic example of how precautionary regulations aimed at reassuring the public can have the opposite effect.”

Precautions inherent in the Cartagena Accord for introducing GM crops into the developing world have served – intentionally or inadvertently – to inform people in those countries that GM crops represent special danger – unlike all other methods for genetic improvement.

That brings me to a June 2018 paper by Kolodinski and Lusk, entitled Mandatory labels can improve attitudes toward genetically engineered food. It purports to show that the introduction of mandatory labelling of GM-containing foods in Vermont led to a “19% reduction in opposition to GE foods.” Given that this paper has received international attention and has been cited several times as proof that the labelling approach works to quell public concern, I’ve discussed it in some detail, below.

The research involved telephone survey opinions of Vermont residents on five dates between March 2014, about the time the Vermont legislation was passed, and March 2017, well after the date of enactment of the Vermont law in mid 2016 and it’s negation by a federal law four weeks later. Those surveyed were asked to give a 1 to 5 answer to the question, “Overall, do you strongly support, somewhat support, have no opinion, somewhat oppose, or strongly oppose the use of GMOs in the food supply?” The authors compare results from this survey to a US national on-line survey repeated on about the same dates with the question: “How concerned are you that the following pose a health hazard in the food that you eat in the next two weeks?” The authors attempt to equate the two surveys, using the differential between two-survey results on the five different dates to judge relative attitudes in Vermont compared to those nationally. But in truth, the comparison is very weak given the very different nature of the two questions and survey methods – and the authors do acknowledge that somewhat.

The authors use several different statistical models for analysis but all methods essentially divide the survey results into two time categories – three surveys completed before July 1, 2016 versus two after – with the assumption being that the existence of labelled food in grocery stores beginning July 2016 was the dominant factor in influencing/changing public attitudes.

This assumption, in turn, is based on a more basic assumption/statement that, to use their words, “there were no accompanying campaigns by pro- or anti-labeling groups designed to sway voter’s attitudes toward GE.”

But knowledge of the political system says this is highly unlikely. Almost every high-profile government law is implemented after lots of lobbying by interested groups and public campaigns – based on the knowledge that politicians mostly do what public pressure tells them to do. That would seem especially true for a highly charged issue like GM labelling. Remember that the legislative debate in Vermont followed high-profile public plebiscites on mandatory labelling in California and Washington State.

Indeed, a Google check tells us that the authors’ statement and assumption is clearly false. Take a minute to check this web site by a group called VT Right to Know GMOs listing many dozens of public events/rallies dating back to 2012. Even Vandana Shiva spoke to pro-labelling rallies in Vermont .

A related web site demonstrates the local and national media frenzy which existed in 2014 as the Vermont bill was being debated/approved.

An intriguing fact about the VT Right to Know web site is that all of its entries cease after August 4, 2016. Up until that date there are massive postings, one or more per week. After that date, total silence. It’s as if this activist group closed up shop and moved elsewhere – maybe back to the USRTK home base in Oakland, California.

When I tried a Google media search for the year 2017 with the words ‘Vermont’ and ‘GMO’ or ‘genetic engineering,’ I came up with almost nothing.

Of course, this fits a narrative that once mandatory labelling is in place, everything quietens down and the anti-GM folks are satisfied. A more likely explanation, at least to me, is that given the shift of national focus away from Vermont, why would any mainstream national NGO spent time in a tiny state with slightly over 600,000 residents (about 0.2% of the US)?

But is this really what we could expect on a larger national scale? Why would anti-GM folks stop with mandatory labels when their stated goal is much larger?

I don’t live in Vermont but my guess is that there was huge public attention peaking in 2014 and that it was maintained as the state and nation watched to see if court challenges by major biotech companies on the legitimacy of the Vermont law were successful. (They weren’t but this process continued until September 2016.) After that, as noted above, all GM-related attention left Vermont.

A final question is the extent to which food products were actually labelled during that window between July 1 2016, when the Vermont law came into force, and July 27, when negated by US statute. Kolodinsky and Lusk are vague on that matter.

Not finding much on the web, I contacted my friend Dr. Mary Mangan (@mem_somerville) in Boston and she provided this report. (Thanks also to .) While totally anecdotal it does describe the 3-6 month phase-in which Vermont grocery retailers had after July 1, 2016 for compliance. Vermont shoppers were obviously exposed to some GM food labelling but we may never know how much.

And that brings us back to the Kolodinsky and Lusk data. They show these average survey ratings in Vermont for the five dates, with a ‘5’ meaning strongly oppose GMOs, a ‘1’ meaning strongly support and a ‘3’ meaning neutral.

Survey date
March 2014 March 2015 March 2016 Nov 2016 March 2017
Average rating 3.714 3.775 4.012 3.474 3.715
Standard deviation 1.007 1.0337 1.183 1.367 1.159


The most intriguing result for me – i.e., beyond the statistical reality that all survey numbers are the same – is that the level of concern at the beginning and end of the three-year survey period was identical, 3.71.

Personally, I might have expected greater concern in March 2014 given that this coincided with the legislative vote, local media hype, and related VT Right to Know efforts.  It may have taken some time for the sustained frenzy to trigger greater public concern; hence, higher values in 2015 and early 2016. The drop in Nov 2016 might have represented a local view that the ‘problem is solved’ and the fact that USRTK had left the state. But why is there such a rebound in public concern from Nov 2016 to March 2017? That rebound is ignored in the authors’ discussion.

(At the risk of adding complexity, I note the authors make much of differences in average scores between the Vermont and national surveys on the five dates. While, personally skeptical about the validity of this, I do note in their data that the national average score descended from 3.360 in Nov 2016 to 3.188 in March 2017, even as the Vermont score rose. Whatever happened in Vermont was probably local.)

So what do we learn from this paper about the experience in Vermont. My impression is not very much. And this is before considering that the definition of GM used in the Vermont legislation was tailored to provide key exemptions to accommodate special state interests, notably dairying – a taste of what lies ahead as special interests lobby in Washington to have their interests addressed in whatever emerges as the national standard.

I suppose the study served a useful purpose for those looking for support for their prior opinion that mandatory labelling is the way to go. For farmers with major concerns about the risks to personal income and family wellbeing, the doubts remain as big as ever.

Ontario Bee Association lobbies for far greater limits on pesticide seed treatments based on flawed environment ministry data

Bee photo

Less than half of Ontario corn seed was neonic-treated in 2017; however, 78% of planted acreage was neonic treated.

What, that can’t be right, you say.

Oh yes it is according to data released recently by the Ministry of Environment and Climate Change (MOECC), and there are more surprises in a recent ministry report on neonic corn and soybean seed sales/usage.

A comparison between 2016 and 2017 numbers in the ministry data shows some other strange findings. The MOECC data show the seeding rate per acre for corn increased 23% in 2017 versus 2016. Total Ontario corn acreage in 2017 is calculated at 3.3 million acres using the ministry numbers – almost 40% higher than reported by Statistics Canada.  Usage of Poncho (chlothianidin) for corn jumped 107% in 2017 versus 2016, say MOECC numbers, even though seed industry contacts tell me they know of no such shift.

The MOEC data are equally weird for soybeans.

The ministry numbers and a related report can be found here and here.

Well so what, you ask?  Obviously just another screwed-up government report which will likely be corrected in the course of time.

The problem is that the Ontario Bee Association (OBA) has used the information to lobby for some rather draconian changes.

It has proposed even more stringent rules for neonic seed treatment for corn and soybeans, an upper limit of 20% of seed for any farm regardless of soil assay results for wireworm and white grub presence. They want the restriction expanded to include winter wheat and sweet corn. They imply that “Schedule 12” type restrictions might be extended to other insecticides like Lumivia and to fungicides.

OBA blames Certified Crop Advisors (CCAs) for the continued substantial usage of neonic seed treatment in 2017 – even though treatment needs for 2017 could be determined entirely using field assays done by farmers.  (The requirement for CCAs-only begins with the 2018 crop.)

The OBA focus on crop pesticides as a priority concern seems very much at odds with what Ontario beekeepers themselves report as their problems. For example, an OMAFRA survey report (it can be found here) on causes of 2016-17 overwinter losses shows that beekeepers consider starvation,  poor queens, ineffective varroa control, and weak colonies were the priorities, along with “other” and “don’t know.”  National reports from the Canadian Association of Professional Apiarists in 2016 and 2017 (link here) do not identify pesticides as a major cause of deaths in any province – indeed, do not even mention neonicotinoids as a cause. The Pest Management Regulatory Agency reports complaints from beekeepers about pesticide-induced losses have dropped 80-90% since 2014.

I don’t blame OBA for the flawed data from MEOCC but it’s disappointing to see their continued vendetta against crop pesticides and their recent pitch to government which is weak, poorly researched, and ignores critical new information from both OMAFRA and Ontario researchers.

I recommend that those involved in grain growing and the farm service industry in Ontario not ignore this request from the Ontario Bee Association. A similar pitch made by OBA to the Ontario Premier just before the 2014 election led to the highly complex procedures which we now follow for neonic seed treatment.

The OBA letter to ministers can be found here.

My letter to minsters in response, which contains much more detail relative to comments made above, follows:


April, 2018

To: Minister Jeff Leal, Ontario Minister of Agriculture, Food and Rural Affairs, Minister Chris Ballard, Ontario Minister of Environment and Climate Change, and Ontario Premier Kathleen Wynne

Re: Request from Ontario Bee Association for further restrictions on pesticide usage for food crop protection.

Dear Ministers Leal and Ballard and Premier Wynne:

The March 7 request from the Ontario Bee Association (OBA) for major additional restrictions on pesticide usage for food crop protection in Ontario is based on some seriously inaccurate statistics, flawed interpretations and a lack of reference to critical new information from the Ontario Ministry of Agriculture, Food and Rural Affairs (OMAFRA), Health Canada, and the University of Guelph. Details are provided below.

The OBA request is based in part on data published by the Ministry of Environment and Climate Change (MOECC) apparently demonstrating only a 22% and 27% reduction in the respective Ontario corn and soybean acreage planted with neonicotinoid-treated seed between 2014 and 2017 ( . The source of those data is here, (OBA modifies the analysis to calculate only a 16% reduction for soybeans in 2017, but that’s of peripheral significance to the discussion below.)

Unfortunately, an analysis of those statistics shows they cannot possibly be correct.

Consider the following table in which I have reproduced the MOECC data, adding some calculations based on the MOECC statistics.

Corn Soybeans
Growing season 2016 2017 2016 2017
Acreage with imidicloprid-treated seed 52,413 48,861 264,841 478,632
Acreage with chlothianidin-treated seed 713,614 1,475,230 NA NA
Acreage with thiamethoxam-treated seed 870,337 111,866 1,106,636 862,476
Tonnes of neonicotinoid-treated seed 15,650 19,296 42,306 42,243
Tonnes of untreated seed 5,061 19,705 35,926 78,158
Total neonicotinoid-seed-treated acres (MOECC data) 1,636,384 1,635,957 1,371,477 1,341,108
Kg seed/acre – neonicotinoid-treated seed, based on MOECC data (% of 2016) 9.6 11.8


30.8 31.5


Total untreated acres (assuming same seeding rate per acre as with treated seed) 529,185 1,670,633 1,164,649 2,481,318
Total Ontario acreage, MOECC data*

(% of 2016)

2,165,569 3,306,590*


2,536,125 3,822,426


Total Ontario acreage, OMAFRA data

(% of 2016)

2,265,000 2,420,000


2,710,000 3,075,000


MOECC/OMAFRA 96% 137%* 94% 124%
*Note that the calculated acreage planted with both treated and non-treated corn seed in 2017, based on MOECC data, would be 23% higher than shown in the table (i.e., to a total of 4,064,350 acres) if the seeding rate per acre was the same in 2017 as in 2016. This, in turn, would increase the MOECC/OMAFRA Ontario corn acreage ratio to 168%.


There are a number of serious anomalies to note:

  • The total number of corn and soybean acreages estimated by MOECC increased dramatically from 2016 to 2017 compared to OMAFRA data showing much smaller changes. OMAFRA data are at: .
  • MOECC data indicate that 23% more treated corn seed (19,296 versus 15,650 tonnes) was used to plant virtually the same acreage in 2017 as in 2016. This is not credible. This distortion means that the error in the MOECC-data-based estimate of total corn acreage in 2017 is actually about 68% compared to OMAFRA statistics (see note to table). That’s a huge discrepancy.
  • The MOECC data show huge changes in the relative amount of seed and acreage treated with the different neonicotinoid chemicals between 2016 to 2017 – for example, an increase of 761,616 (+107%) in corn acres treated with chlothianidin from 2016 to 2017 and a reduction of 758,471 (-87%) in acres treated with thiamethoxam. Large swings are also shown for soybeans. However, my personal check with seed companies which sell an estimated 90% or more of the corn and soybean seed in Ontario revealed no comparable changes in the reported relative use of the respective products in 2017. (A notable exception is the largest seed corn seed supplier in Ontario which abandoned almost all usage of neonicotinoid seed treatments in 2017, using another, newer insecticide, safer to pollinators, as a replacement).

In brief, the data provided by MOECC cannot be correct, and any conclusions based thereon – at least until the ministry corrects the errors – are equally erroneous. I am tempted to point out the dramatic increase in the planting of seed not treated with neonicotinoids in 2017 versus 2016 in the MOECC data, but must assume that these statistics are also highly unreliable.

The Ontario Bee Association blames Certified Crop Advisors (CCAs) for a claimed substantial usage of neonicotinoid-treated corn and soybean seed in 2017 – perhaps because of non-familiarity with the details of Ontario Regulation 139/15 to the Ontario Pesticides Act (June 2015). The regulation states that purchases of neonicotinoid-treated corn and soybean seed (i.e., Schedule 12 pesticides) for 2017 could be based entirely on farmer assays for the presence of wireworms and white grubs in farm field soils. The regulatory requirement for the use of CCAs did not start until seed purchases for the 2018 crop season, now just beginning (and even then for only a few counties/regions).

The OBA also claims that provincial average crop yields increased (corn) or did not change much (soybeans) from 2014 through 2016 and 2017, thus apparently demonstrating that insecticide seed treatment is not important to yield. OBA needs to recognize the dominant effect of other factors such as seasonal differences in weather and genetic improvement on crop yields.

The OBA letter claims without evidence that the number of claims of loss reported to PMRA-Health Canada is down since 2014 (actually down 80-90%, because bee keepers have no incentive to report losses. The much more logical explanation is that claims are down because the there are fewer incidents to report, possibly because of changes in seed treatment procedures mandated by PMRA before the 2015 crop season. Happily, percent over-winter losses have declined substantially in Ontario (average of 28%, 2015-2017) since the very high percentage (58%) in 2014, even as the number of honey bee colonies remains well above that of a few years ago.

I am especially disappointed in the OBA request that Province’s very restrictive policy on seed treatment with neonicotinoids be extended to winter wheat, even though wheat produces no pollen or nectar to attract foraging bees – and also to include other insecticides being introduced despite their low toxicity to honey bees. They even suggest inclusion of fungicides perhaps based on very minimal evidence from laboratory work (notoriously unreliable for predicting effects on bee colonies in the real world; see more on this at ). One gets the impression that OBA is most interested in restrictions on agricultural pesticide usage as a goal in itself – though apparently (hopefully) not for pesticides needed to address in-hive pests that harm bees, e.g. varroa treatments.

Also, a note about the assumption in some public statements that only 20% of Ontario corn and soybean acreage needs insecticide seed treatment for control of insects like wireworm, white grubs and seed maggot: My understanding is that this comes from an educated guess which an OMAFRA specialist provided at an OMAFRA-chaired working group meeting. There is no reference to any such goal in Ontario Regulation 139/15 to the Ontario Pesticides Act. OBA is incorrect in stating in its March 7 letter than this a stated aspirational target in “passed legislation.”A far more accurate assessment of need will be available from the extensive assays mandated under Ontario Regulation 139/15, especially when this process is managed by CCAs, beginning in the 2017/2018 reporting year (2018 growing season). Presumably the Ontario goal is to use neonicotinoid-treated seed on those corn and soybean acres which require treatment as identified by the Integrated Pest Management processes described in the Regulation. That need may well prove to be significantly higher than 20%.

Each year the Canadian Association of Professional Apiculturists (CAPA) (mainly government and academic bee specialists across Canada) does a survey of over-winter honey bee colony losses across provinces and reports both the loss statistics and results of a survey of beekeeper impressions on the reasons for losses. Neither the 2017 nor 2016 reports list pesticides as a principal cause of colony deaths in Ontario. Indeed, the word ‘neonicotinoid’ does not even appear in either report. The 2017 report is here: .

This finding matches the survey information provided by the OMAFRA report on over-winter bee losses, . A table from that report is shown below. Pesticides, at least other than those used directly on bees (see “ineffective varroa control”), are not listed as a major factor.

Ontario Apiarist bee losses

In 2017, a major report from the University of Guelph, commissioned and funded by OMAFRA, was released showing that while pesticides do affect bee health, bee pests such as varroa mites, and inadequate bee management are dominant causes of over-winter bee mortality in the province. The full 238-page report is here: A shorter summary is provided here:

Also in 2017, a team at the University of Guelph, including internationally recognized pesticide toxicologist Keith Solomon, completed a mega-review of world literature on the effects of neonicotinoid seed treatments on honey bee colony health. Their conclusion is summarized succinctly in the news release title, “Correctly used neonics do not adversely affect honeybee colonies,” .

The Pest Management Regulatory Agency of Canada released statements of intended regulatory changes for chlothianidin and thiamethoxam in December 2017 and an equivalent statement is expected, imminently, for imidicloprid, PMRA proposed no changes in usage of seed treatments for chlothianidin and thiamethoxam other than a labelling change for cereal-crops and forage-legume seed.

In an earlier report, PMRA estimated the economic benefit to Canadian corn and soybean farmers to be in excess of $100 million annually, .

The preceding comments pertain mainly to effects of neonicotinoids on honey bees. Little is known about the vitality of wild bee colonies in Canada/Ontario or the effects of various pesticides. (See 2017 University of Guelph reports cited above.) There is growing evidence that honey bees may be one of the largest threats to wild bee well-being – both through the competition provided for wildflower nectar and pollen – and for the role of honey bees in spreading bee diseases to wild species. A major overview can be found here: .

In closing, I commend the Ministries of Agriculture, Food and Rural Affairs and Environment and Climate Change for their continuing work on pollinator health and encourage them both to focus on threats that both individual beekeepers in Ontario and good science judge to be most important ones. Conversely, please be cautious in being swept up by the quite contrary, anti-pesticide agenda promoted by the Ontario Bee Association. Finally, I encourage MOECC to re-examine the base data used to provide annual reports on Schedule 12 pesticide usage (neonicotinoid-treated corn and soybean seed). The most recent report provides a data summary which contains so many discrepancies as to be largely meaningless.


Terry Daynard

In Praise of Pesticides: Let’s stop assuming that complete pesticide elimination is a laudable and realistic goal – for it is neither

Spraying field

In about 1980, I visited several CIMMYT research sites in Mexico. The trip included a tortuous drive to a low-elevation research station near Poza Rica. As we rounded one bend, I vividly remember seeing an ejido farmer hoeing weeds in his half-hectare corn field. “He is always there,” I was told, day after day under the hot sun. When he progressed to one side of the field, newly emerged weeds already needed hoeing on the other.

What a tedious task I thought, as I compared that to my own corn fields in Ontario. For me, one spray application at a cost of about $20 per half-hectare, and less than 5 minutes of field work, meant near weed-free conditions for the whole growing season.

Efforts to control pests are as old as farming. With weeds at least there has always been the option of hand-pulling, hoeing, and/or small cultivators pulled by animals (more recently, tractors). Diseases and insects were worse because mechanical control was usually impossible and high pestilence meant extreme crop losses, and often starvation.

John Unsworth in History of Pesticides states, “The first recorded use of insecticides is about 4500 years ago by Sumerians who used sulphur compounds to control insects and mites.” Over the millennia, lots of approaches have been tried.

A big change occurred in about 1940 with the discovery, manufacture and usage of two synthetic compounds – 2,4D for weed control and DDT for insects. Many other synthetic herbicides, insecticides and fungicides soon followed.

I remember the excitement in about 1962 when Professor George Jones of the Ontario Agricultural College (now part of University of Guelph) applied atrazine to a small field of corn on campus and killed almost every weed for the full season – thereby eliminated the historic need for “scuffling” (inter-row cultivation after planting) for weed control in corn.

In years since, crop agriculture everywhere in the developed world (most developing countries too) has become highly dependent on chemicals for pest control.

Insects eating plant leaves

Crop pests, if not controlled, mean less food

This did not mean a diminished effort by plant breeders to develop new pest resistant crop varieties. But plant breeding is slow; genetic sources of pest resistance are often hard to find or unavailable; and genetic resistance usually ‘breaks down’ (pests become resistance) with time. Plant breeding is highly important to pest management but it’s insufficient by itself.

Of course, genetic resistance of pests to pesticides also develops, and herbicide usage has meant a shift in weed populations; new species tolerant to specific herbicides become more prevalent when competition from herbicide-susceptible ones disappears.

Notwithstanding the challenge of evolving pest resistance, the combination of better plant breeding techniques and new pesticides means pests are controlled far more effectively now than in times past. That’s one major reason why yields of many crops have increased dramatically in recent decades.

The advent of chemical weed control also triggered some important changes in cropping techniques. One was no-till crop planting which now represents a very common cropping practice for many crops and regions.


The increased usage of chemical pesticides also meant growing awareness of the negatives. Rachel Carson’s book, Silent Spring, published in 1962 was pivotal.

That event coincided with a growing public awareness of many environmental issues, and greater restrictions were soon placed on pesticide usage. Many early pesticides were banned for usage, DDT being one. Newer pesticides are safer to both human health and environment than those of earlier years.

Sustainability is a strong driver of twenty-first century agriculture. Virtually every agricultural and food organization now lists sustainable development as a priority. Despite the common goal, sustainable agriculture has come to mean many different things.

Sustainable agriculture

Organic agriculture which rejects the use of synthetic pesticides and some modern crop breeding technologies often defines itself as ‘sustainable’ even though the environmental benefit is mixed (see also here) and this approach generally means significantly lower productivity per hectare and higher food prices.

Genetic engineered (GE) crops, commonly called genetically modified crops or organisms, or simply GMOs, have generally meant reductions in pesticide usage and/or the use of pesticides safer to human health. Many view this as more sustainable.

Despite their differences, a common view shared by supporters of both organic agriculture and genetic engineering is that pesticide usage is inherently bad. It’s seen as a necessary evil, with a goal of sustainable agriculture being to minimize and ultimately eliminate pesticide usage.

UK environmentalist, Mark Lynas, who I admire a great deal, stated in a recent talk, “let’s get serious about getting crop protection chemicals out of farming.”  He’s not unique in equating sustainability with ‘pesticide free.’

But when you search deeper, the rationale for a goal of elimination seems vague and weak.

Yes, there are and will always be risks with pesticide usage, risks that are larger where reasonable precautions are not taken to minimize human exposure (too common, I’m told, in many developing countries). Off-target pesticide drift is also an issue. Farmers and other pesticide users too often apply pesticides prophylacticly rather than in response to specific threats. Better means of predicting need are required. Finally pesticides cost farmers money and require the use of some energy for their production and transport to users.

risks to health and environment with pesticide usage must be balanced against the often-larger risks associated with pests and pest-induced toxins in food which pesticides help control.

Alternatives to pesticides also have notable downsides for both health and ecology. Take soil cultivation as an example. It causes the more rapid oxidation (breakdown) of soil organic matter, renders soils more vulnerable to water and wind erosion and can be devastating to soil organisms. Pests adapt to cultural controls just as with pesticide usage and plant breeding.

Tillage and erosion

Soil tillage means more soil erosion


Everything we do in agriculture involves a balance among competing needs for food productivity, environmental integrity, and the ability of farmers to earn a living.

A reduction in pesticide usage in agriculture makes sense where effective alternative controls are available at affordable cost, and where the health and environmental risks of the alternatives are less than that of the chemicals they replace.

But reduction is not the same as elimination.

A recent Bloomberg news article about some entrepreneurs developing robotic weeders is telling: “After months of research [with robots on non-chemical weed control] they faced a disappointing truth: There was no way around herbicides….Their challenge became applying the chemicals with precision.”

The nature of pesticides will likely change. New approaches show great promise, such as ‘RNA interference’ which involves the use of compounds designed to block the action of specific genes and the enzymes they code for in specific pest organisms and/or crop plants.

But even as these are introduced, the pests will inevitably evolve to develop resistance, just as occurs with plant breeding and more traditional pesticides.

So it comes down to the subtle but important distinction between low and no pesticide usage. Reductions in pesticide usage are to be applauded where possible and net beneficial, but hopes for a total elimination of all pesticide usage in crop/food production are not realistic – at least with technologies now available or on the horizon.

This assumes of course that the goal truly is sustainable agriculture – and sustainable in the sense that agricultural technology must continually evolve and improve to address ever-changing needs and pest threats.

Of course, if the goal is pesticide elimination per se regardless of sustainability, then I suppose pesticide elimination makes sense. (Just make sure you don’t eliminate DEET-based mosquito repellents, Lysol® use in bathrooms, or common pesticides used for flea control on pets and head lice on children; insert emoji for irony here.)

It would not be possible to feed 7.6 billion people today without pesticides – let alone the 9-10 billion expected by 2050. So as well as being cautious and sparing in pesticide usage, let’s also give them some praise. Let’s thank pesticides for what they have contributed to human well-being for so many years, and will in decades to come.

And let’s stop assuming that complete pesticide elimination is a laudable and realistic goal – for it is neither.



York-Laval University Paper on Neonics and Bees Marred by Inconsistencies, Data Deficiencies, Dubious Bee Management and Weak Statistics


Two new research reports purporting to show serious negative effects of the neonicotinoid insecticides (neonics) on the health of honey bees were released in late June, 2017. One was one a major European study involving trials in Germany, Hungary and the United Kingdom (UK), and the other done by Tsvetkof et al at York and Laval Universities in Canada. (Tsvetkof et al paper is also available here.)

Reviews of the European study have been done by Iida Ruishalme and Jon Entine. In brief, a careful examination of the data (though not the authors’ conclusions) shows mostly no effects, positive or negative, of neonic exposure on bee health. Interestingly the senior author of this paper, B.A. Woodcock, was also senior author for a 2016 paper attempting to use a correlation between declining UK bee numbers and increasing neonic usage over a period of about two decades, to prove that the latter caused the former – see here, here and here for more.

This commentary is about the Tsvetkof et al paper. My conclusion, in brief:

This paper joins others in showing that honey bees exposed to high concentrations of neonics (in this case clothianidin) may demonstrate sub-lethal effects. However, the strength of this conclusion is weakened seriously by data inconsistencies and deficiencies, major questions about bee management, and dubious statistical analyses. The potential role of varroa mites and other pests and diseases is ignored.

To learn how I reached that conclusion, read on.

In 2014, the authors placed a total of 55 bee hives at 11 locations in Ontario (mostly) and Quebec, with five being within 0.5 km of a corn field and six located more than 3 km from the closest corn field. They sampled the level of several pesticides, including insecticides, herbicides, fungicides and a miticide, in living bees, dead bees, pollen and nectar in/near the hives at six times between early May and September. The data are shown for each location–by-time combination in a supplemental table provided by the authors.

Tsvetkof et al then took the average quantifiable concentration of the neonic clothianidin measured in pollen samples within hives in 2014 and used it as the basis for pollen concentrations of clothianidin to which bee colonies at York University in Toronto were artificially exposed (five colonies were exposed, five were not) in a study in 2015. The concentrations used as the base were not the average of all samples measured the previous year but, rather, the average of those high enough to be quantified (i.e., 15 of the 66 location x time combinations). Both the treated bees (fed clothianidin-laced pollen blocks) and the check (no clothianidin in pollen blocks) were also exposed to the fungicides dimethomorph and boscalid, preservatives in the pollen blocks. Worker bees from the five treated and five untreated colonies were collected, radio tagged, placed collectively in a single observation chamber, and the activity of these bees was monitored.

In another 2015 experiment, the authors fed five different dosage levels of clothianidin and thiamethoxam, in sucrose-acetone solutions, and in combinations with or without boscalid (497 ppb) and the herbicide linuron (7 ppb), to caged worker honey bees. They calculated acute LD50 values for the two neonic compounds (4 hr exposure to chemical mixtures; mortality measured after 24 hr). Relatively few details are provided on how this was done.

The authors reported that worker bees exposed to the neonic clothianidin in 2015 died younger and were less hygienic (propensity to remove dead bees from hives) than unexposed bees, that queen mortality/functionality was reduced with clothianidin exposure, and that the LD50 for clothianidin was reduced in the presence of a high concentration of boscalid. Some differences were observed in the foraging patterns of tagged worker bees.

I have reviewed the paper and the supplemental information which the authors have provided and have a number of major concerns about their experimental protocols and results.

Concentrations of neonics in bee-collected pollen

The concentrations of neonics in pollen which they collected from hives in 2014, and summarized in the following tables, seem very high.

Time of sampling Hives near corn Hives not near corn
Average clothianidin concentration, ppb (number of sites/total sites)
1 4.5 (2/5) 4.1 (1/6)
2 6.6 (4/5) 2.1 (3/6)
3 2.2 (2/5) 8.5(1/6)
4 2.6 (2/5) Not detected
5 Not detected Not detected
6 Not detected Not detected


Time of sampling Hives near corn Hives not near corn
Ave. thiamethoxam concentration, ppb (number of sites/total sites)
1 2.2 (2/5) 2.0 (1/6)
2 5.0 (3/5) 2.0 (1/6)
3 3.3 (2/5) 8.7(1/6)
4 3.0 (1/5) Not detected
5 1.1 (1/5) Not detected
6 Not detected Not detected

Note that these high concentrations don’t originate from the pollen of treated corn or soybeans. Corn pollen was found in only one of 21 neonic-positive samples and soybean pollen in only five of 21 and neither ever represented as much as 1 % of the pollen collected. The high concentrations came from other plants both near or more than 3 km away from, corn fields. The authors provide no information on proximity to soybean fields or other plants which may have been deliberately treated with neonics, other than to state that soybeans are grown near corn. Notably, two of the three “far corn” sites where concentrations of neonics were quantifiable in hive pollen (above 8 ppb for both clothianidin and thiamethoxam for one of these sites!) are within the cities of London and Toronto, Ontario and apparently remote from agricultural production. No explanation is provided is provided as to the source of this neonic exposure.

While not central to the theme of this paper (since the authors state that this compound is not of concern for bee well being) a very high concentration of 329 ppb of acetamiprid, another neonic, was measured for one “near corn” pollen sample in Quebec, but with no explanation provided as to source.

I have compared those reported values for clothianidin and thiamethoxam with others in the literature.

Blacquière et al (2012) provide a summary of published measurements of neonic concentrations in bee pollen including results of one extensive survey over three years in France. In it, imidicloprid was found at concentrations (where detected) at 0.9 to a maximum of 3.1 ppb though with no information available as to the source of the insecticide. Other European data cited by Blacquière et al involving imidicloprid, clothianidin, and imidicloprid (the three neonics generally used as seed treatments), generally show lower concentrations in pollen collected by bees, typically under 1 ppb and quantifiable in less than 1% of the assayed samples.

Stewart et al (2014) measured the concentration of neonics in pollen/flowers of seed-treated corn, cotton and soybean fields in Tennessee, Mississippi and Arkansas, in adjacent wild flowers, and in pollen collected by honey bees for colonies positioned an average of 180 m from the treated fields. Only 23% of samples (of whole plants, not just pollen) had neonic concentrations about 1 ppb, but the others ranging up to 257 ppb. (The highest sample came from a place where the farmer filled the planter with treated seed.) The arithmetic mean for all samples was 10 ppb. Neonics were measured in corn pollen at average concentrations of 0.4 to 5.6 ppb (and as high as 23 ppb for an individual sample) depending on compound used (higher for clothianidin than thiamethoxam) and the seed-treatment rate, but only at much lower levels for cotton pollen (almost all under 1 ppb) and not at all in soybean flowers. Most significantly, neonic concentrations above 1 ppb were detected in only 2 of 74 pollen samples collected from foraging bees despite their nearness to treated fields.

Long and Krupke (2015) in Indiana measured a mean concentration of clothianidin of 0.64  ppb (maximum 9.4) in 32 samples of pollen collected by bees for hives located immediately beside a treated corn field.

Botias et al (2015) in Sussex England measured the neonic concentration in the pollen of wild flowers adjacent to an oilseed rape (OSR) fields sown using thiamethoxam-treated seed and adjacent to wheat field grown from clothianidin-treated seed. They also measured neonic levels in the pollen collected by bees colonies positioned on the same farms. They found thiamethoxam concentrations averaging 15 ppb in wild flowers next to the OSR, but almost no clothianidin in flowers next to wheat fields. However, the maximum concentration in pollen collected by bees at the time of OSR flowering was 1.8 ppb for thiamethoxam and 1.2 for clothianidin (averages 0.2 and <0.1, respectively). Curiously, pollen collected by bees at time of OSR flowering contained an average of 2.5 ppb imidicloprid even though this had not been applied to either field for three years and field-adjacent wild flowers averaged less than 1 ppb.

Cutler and Scott-Dupree (2007) measured the concentrations of clothianidin in pollen collected by bees colonies located in the middle of four Ontario canola fields grown from clothianidin-treated seed. The maximum concentration of clothianidin measured in any pollen sample was 2.6 ppb. A similar though larger experiment, which was reported on in 2014, yielded a maximum concentration of 1.9 ppb.

How does one get concentrations in bee pollen of 8.5 ppb for clothianidin plus 8.7 ppb for thiamethoxam in colonies located in the city of London Ontario, remote from agriculture, but only a maximum of 2.6 ppb for hives in the neonic-seed-treated canola fields in bloom?

While the results of Tsvetkof et al generally do show more neonicotinoids in colonies nearer corn fields, they do not show that corn fields are the dominant source – indeed, they cannot be for the three within-city sites remote from corn fields, where neonics were measured in bee pollen at sizable concentration.

I do note that high neonic concentrations have been measured by other researchers in pollen collected by bees near agricultural crops. Pohorecka et al (2013) measured an average concentration of 27 ppb of clothianidin in pollen collected in pollen traps for bees returning to hives positioned in a corn field in Poland, though the concentration of clothianidin in “pollen bread” found within those hives was below the level of detection. Pilling et al (2013) also found much lower concentrations of neonics in “bee bread” than in pollen collected from returning worker bees.  Dr. Schaafsma at the Ridgetown campus of the University of Guelph has told me in personal communication that he has measured levels of neonics in pollen collected by bees at least comparable to those measured by Tsvetkof et al.

Bee health and management

The authors state “we did not chemically treat the colonies to control hive pests or diseases” in describing the 2014 research protocol and the same for the research in 2015. This is despite the fact that varroa and other pests/diseases are the dominant cause of poor health in Ontario/Canadian bees (see here for example), and chemical treatment for control of one or more pests/diseases, at least for varroa, is standard practice. Not only were no varroa-control treatments applied, but there is no mention of this potential complication for the research results – other than a simple statement that bees appeared visually to be healthy at the beginning of the trials.

This neglect is in marked contrast to the approach used by other researchers. For example, Pohorecka et al (2013) in Poland were very careful to monitor the prevalence of varroa mites and of several bee viruses in their research and bees were treated with Apivar for mite control. The Polish researchers measured no significant effect of exposure to either clothianidin or imidicloprid treated corn fields on any measure of colony health. Perhaps their diligence in controlling varroa is why.

Interestingly, the most common chemical found in bees, pollen and nectar in 2014 results of Tsvetkof et al was coumaphos, an organophosphate compound used for mite control in bees.  Coumaphos was measured in 91 samples in total as compared to clothianidin in 26 samples. Coumaphos was once commonly used for varroa control in Canada though I understand not so much lately because the mites have developed resistance. The origin of the coumaphos detected in this study is unknown; perhaps the hives were treated with it before the experimental period began. According to this Cornell University document, “Coumaphos poses a moderate hazard to honey bees and a slight hazard to other beneficial insects.”

There is no mention of the presence of other miticides in this study – likely because they were not in the list of chemicals assayed.

There is a good amount of published information showing that bees are more vulnerable to insecticides, including neonics, when weakened by varroa and other bee pests/diseases (example here). Were varroa mites, bee diseases and other pests the cause of the sub-lethal effects reported by Tsvetkof et al? No one knows because the researchers ignored this possibility and provide no relevant information.

The authors present a graph from their 2015 research purporting to show that bee queen health was worse for colonies artificially exposed to clothianidin versus those which were not. It’s graph D in the following figure from their paper. The blue dots and line are for the control treatment; yellow for treated. First, it’s doubtful, with so few data points, whether those lines really are different at P<0.05. In fact only four data points are graphed for the treated hives though I suspect that at least one additional data point may be hidden under an identical value for the control. More pertinent to this discussion is the question: how does a check treatment with only 20% of hives having functioning queens (i.e., the check treatment at about 55 days) represent proper bee management? I’m told that this would be major cause for concern if it happened in a commercial bee yard. One suspects that there was a serious management problem with these colonies at York University (perhaps poor control of varroa or diseases?).

Zayed Fig 2a

Zayed Fig 2

Statistical analyses

While I don’t profess to be a good statistician myself, I wondered about the validity of some of the statistical analyses performed by Tsvetkof et al. As a result, I checked with statistician Bill Price at the University of Idaho. Among his comments he noted the small number of data points (two) and low degrees of freedom (n=4) used distinguish the two lines in Fig 2B above.

More problems exist with graph D above. Firstly, it is highly unlikely that the two lines shown differ significantly given the scatter of the data especially for the control treatment. But there is also a problem in credibility of the basic data. The numbers for each of the treated and control treatments come from data from five hives. With five samples, how can you have a value of 0.75 for one control measurement? It’s mathematically impossible. (The 0.25 values for the treated hives are explained by the authors; a queen was inadvertently killed by the researchers so that hive was excluded for consideration for the remainder of the trial.)

He also, noted that treated and untreated bees were mixed together in one observation chamber for measurements of the respective flight behaviour and longevity of worker bees in 2015. In effect the two treatments were not imposed independently which makes statistical interpretation difficult.

There are also questions about the procedures and statistical analyses used to determine LD50s (no basic data used in calculations are provided by the authors) but I will not enlarge on that here.

Lack of colony data

A major question with this paper is the lack of colony data. Why did the authors provide no information on colony performance of the 55 hives in 2014? More importantly, why none for the 10 hives located on the York University campus on 2015 as that should have been easy to do? The authors measured a parameter called hygienic behavior (propensity to remove dead bees) in treated and untreated colonies, but there are no data on numbers of workers or dead bees – or on colony size, honey production and subsequent hive survival. (Note that the authors’ use of the term, hygienic behavior, differs from the definition often used by bee keepers in Ontario, which is the propensity to removed varroa mites from other bees.) This void contrast with the work of Pohorecka et al (2013) who measured various colony-level effects and found none – this despite the even larger exposures to clothianidin in pollen in their study.

The authors’ one-sentence conclusion: “Our findings indicate that chronic [neonicotinoid] exposure reduces the health of honey bee colonies near corn crops,” is belied by the fact that they provided no real measurements of colony health (queen vitality being the exception).

In summary

This paper joins others in showing that honey bees exposed to high concentrations of neonics (in this case clothianidin) may demonstrate sub-lethal effects. However, the strength of this conclusion is weakened seriously by data inconsistencies and deficiencies, major questions about bee management, and dubious statistical analyses. The potential role of varroa mites and other pests and diseases is ignored. Also, no consideration is given to the question of what the effect would be if/when neonics are replaced by other insecticides for pest control on food-producing farm crops.


I thank Dr. Bill Price Director of Statistical Programs, College of Agricultural and Life Sciences, University of Idaho, and Dr. Chris Cutler, Associate Professor, Department of Plant, Food and Environmental Sciences, Dalhousie University for their advice on aspects of the Tsvetkof et al paper. However, the comments made in the preceding review are attributable solely to me.

Comments on “Status and Trends of Pollinator Health in Ontario” (A review by Pindar et al., March 2017, University of Guelph)


In 2015, the Ontario Ministry of Agriculture, Food and Rural Affairs (OMAFRA) commissioned a comprehensive review on bee health. The contractor, a University of Guelph group led by Dr. Nigel Raine, submitted its review in April 2016. Eleven months later it was made public via an obscure WordPress posting. The review is lengthy and contains a wealth of information on both honey and wild bees.

The following is for those interested in a quick overview of the review along with my personal comments.

The review provides a well-written description of the many pests and diseases which afflict managed bees. It states, “Pests affecting honey bees in Ontario are varroa mites, tracheal mites, wax moths, and the small hive beetle. Pathogens include numerous species of bacteria, fungi and viruses. Bumble bees, especially managed [Bombus] impatiens colonies, are affected by viruses, the trypanosome parasite Crithidia bombi, tracheal mites, the fungal infection Nosema bombi, and small hive beetle.”

The review joins others in emphasizing the overall importance of varroa mites and related control measures on honey bee well-being in Ontario. “Although beekeepers are actively managing their hives, mite levels are constantly rising in colonies,” says the review. Since 2016, varroa have been found in virtually all colonies. The review reports the difficulty of effective varroa control with genetic resistance developing in varroa mites to several key miticides, and the miticides themselves being quite detrimental to bee health.

The review also describes growing awareness of the importance of bee viruses to honey bee health, to a greater extent than I have seen in other public reports about bee health in Ontario. It notes, as have others, that honey bees weakened by varroa are more vulnerable to several bee viruses than was the case in pre-varroa times. The review notes the slowness of OMAFRA and the Ontario bee industry in introducing routine monitoring of Ontario bee colonies for the prevalence of viruses, in contrast to the regular monitoring occurring in the United States.

The review includes criticisms of beekeeper management in Ontario: “In Ontario, management practices are the second leading cause of overwintering mortality in honey bees after Varroa mite infestation (Guzman-Novoa et al. 2010). Specifically, having weak colonies, with insufficient numbers of workers entering the winter season, and having limited food reserves to carry bees through the winter contributes to their losses.”

Note also this quote: “the declining health of managed bees (honey bees, blue orchard bees, managed Bombus [bumble bee], and alfalfa leafcutter bees) is in part due to their management by humans.”

It is obvious that honey bee management, especially for over-winter survival, is especially challenging in a province like Ontario where hobbyists predominate. The average Ontario bee keeper has about 3-4 hives according to Statistics Canada, versus about 30 in Alberta, by comparison, where commercial production prevails.

The review also focuses on the 39% of Ontario colonies (2016 statistics) which are transported by beekeepers each spring to Quebec and Maritime Provinces for blueberry and cranberry pollination. The review notes that while honey bees are not good blueberry pollinators, this lack of effectiveness is countered by the use of large numbers of colonies per blueberry field – presumably creating stress for the bees themselves.


The review is inconsistent in its statements about changes in honey bee colony numbers. For example, “honey bee colony numbers have continued to decline” (page 26) versus “Over the past 10 years the number of colonies in Ontario has increased by 32.7%” (page 100). The review also includes data showing an upward trend in number if honey bee colonies for all of Canada.

The review includes a graph (“Figure 2,” pasted below) which implies that in Ontario, in contrast to some other provinces, the colony winter loss percentage may be trending upwards. However, if the graph had been updated to show the 37.8% and 17.9% losses reported for Ontario for 2014/15 and 2015/2016 the trend in Ontario would have appeared differently. Statistics provided by the Canadian Association of Professional Apiculturalists for 2013/2014, 2014/15 and 2015/16 are shown in the accompanying table.

(The review is inconsistent in the recency of its data, sometimes using statistics as current as 2016, and sometimes stopping two years earlier as in this case.)



CAPA overwinter bee lossesThe review includes discussion of the 420 wild bee species found in Ontario, including 25 bumble bee species. Unlike some areas of the world (notably the UK and other parts of north-western Europe), there is very little information available on the population status of most wild species. We don’t know whether their numbers are in decline or not. (One bumble bee species, the Rusty Patched bumble bee, Bombus affinis, has likely become extinct in Ontario.)

The review joins other reports in identifying honey bees as a serious threat to the well-being of wild bee species. Honey bees compete directly for nectar and pollen and are vectors for the spread of diseases and pathogens. (Varroa are not a pest of wild bees but the viruses associated with varroa are, and those viruses are spread during consecutive visits by different bee species to the same flowers.)

An argument is made that loss of habitat may be affecting wild bee populations in Ontario/Canada – and it would seem reasonable that this is true in some parts of the province – but there is a dearth of supporting data.

The review lists pesticides as a factor affecting bee health. However, the most serious culprits appear to be the pesticides used to control bee pathogens, especially mites. The review cites three studies from Ontario which have shown no effect of neonicotinoid (neonic) insecticides on honey bee health and notes that neonic effects are much more commonly found in laboratory studies than field research. The review gives attention to possible non-lethal effects of neonics on bees, a special area of research for Dr. Raine. However, the review pays little attention to a criticism that his conclusions are largely based on bee pesticide exposure levels significantly above what is generally found to occur in Ontario fields. (Researchers who evaluate pesticide effects on bees in artificial settings often refer to “field-realistic exposure,” when that is often not the case – especially for multi-day exposure.)

This review gives major attention to a Swedish field study where wild bee species (but not honey bees) showed sub-lethal effects when exposed to neonic-treated, spring-planted oilseed rape (known as canola in Canada). Not mentioned is the detail that the Swedish fields were planted with seed treated at 2.5 times the maximum neonic application rate permitted in Canada (personal communication, Canola Council of Canada).

Disappointingly, the review gives credence to a recent paper from the UK (Woodcock et al., 2016) where the authors claimed that a decline in the heath of several wild bees species was attributable to neonic usage, even though this conclusion was based solely on a correlation over years (neonic usage up, bees numbers down). Telling is this statement in a BBC feature on the Woodcock paper: “The authors acknowledge that their study finds an association and doesn’t prove a cause and effect link between the use of neonicotinoids and the decline of bee populations.” Contrast that with this unqualified statement in the current review, “[there were] significant negative impacts on species persistence associated with neonicotinoid use (Woodcock et al. 2016).” One suspects that a similar correlation between organic food sales and wild bee numbers in the IK would have been equally significant, statistically.

Ignored in the current review is a relevant 2011 Carleton University thesis study by Joanna James, in which she found essentially no difference in wild bee populations beside pesticide- (including neonic-) treated fields versus those receiving no pesticides.


The authors say there is no supporting documentation, other than speculation, for a claim by others that declining wild bee populations are responsible for a decline in the well-being of 78 endangered plant species in Ontario. “Although provincial and federal governments identify the importance of pollinators, such as bees, as playing a key role in the survival for many of Ontario’s rare plants (e.g. results from our systematic literature review found no peer-reviewed or grey literature to support this.”

I am pleased the authors addressed an oft-repeated but rarely documented claim that one-third of food depends on bee-pollinated crops. The authors calculate that $0.9 billion (13%) of Ontario’s $6.7 billion in value of agricultural crop production involves bee-pollinated crops. In another calculation, they estimate that the value of pollinators to Ontario agriculture might be about $540 million per year, of which about two-thirds involves wild bees.

The review, unfortunately, is quite weak in considerations of agronomy and bee-agricultural interactions. Here are some examples:

  • The review states without supporting references that alfalfa production is increasing in Canada because increasing demand for feed and because it is cheaper to plant this crop compared to wheat and barley (page 12). Cost of production data (available here) do not support this claim for seeding costs, and I doubt that the demand for alfalfa-based feed (essentially for dairy and some beef) is increasing in Canada.
  • The authors do not appear to distinguish between alfalfa used for forage (does not require pollination) versus for seed (pollination needed). Indeed, in a table on page 110, the authors imply that the value of alfalfa seed production in Ontario averaged $109 million from 2009-2014. In reality, there is very little alfalfa seed production in Ontario and alfalfa grown for forage production is harvested in the vegetative state, often even before flowers appear.
  • On pages 103 and 106, the authors erroneously dismiss carrots and potatoes as largely insignificant agricultural crops in Ontario.
  • They refer in several places to parthenocarpic cultivars of canola, soybeans, peas, beans, ginseng, tomatoes and other crops, when it is highly doubtful that such exist. They appear to have confused the term, “parthenocarpic” (no fertilization required), for “self-pollinating.” On page 105 they refer to canola flowers being “self-incompatible and depend[ent] on generalist insect pollination.” That’s true for only Brassica rapa canola which represents less than 1% of Canadian production according to industry contacts.
  • There are several undocumented suggestions in the review that fertilizer applications harm bees (see page 132), that manure is better than synthetic fertilizers for pollinator health and a page 124 statement that sowing grasses in rotation enhances soil fertility which makes no agronomic sense. (Grasses do improve soil structure.)
  • They make a claim on page 131 that “Herbicide resistant canola fields have high levels of pesticide used,” apparently unaware of analyses such as that of Smyth et al (2014) showing substantial reductions in pesticide usage with glyphosate-tolerant canola in Western Canada.

The authors imply in other places that organic agriculture is better for crop pollination. They refer to a study by Morandin and Winston (2005), showing more complete pollination for flowers in organic canola versus herbicide-treated fields, a result they attributed to more weeds and more bees. But there are ample data to show it’s the reverse when it comes to canola yield: better weed control means better yields, implying that pollination is not the dominant yield limitation.

Many wild bee species are ground dwelling and one might expect that more frequent tillage with organic cropping (as compared to no tillage plus herbicide usage) would be detrimental to their well-being.


The authors also try to make the case on several occasions that a diversity of wild flowers and pollinators in surrounding areas enhances the yield of major crops, but their case is very weak. Several of the literature citations are only to other authors who have made the same conjecture. On Page 39 they state, “A meta-analysis by Ricketts et al. (2008), found that yield declined due to shortage of pollinators with increasing distances between the crop and natural or semi-natural habitats.” But the Ricketts paper actually says that this relationship has generally been found to be non-existent or not statistically significant.

This is not an attempt to argue on my part that wild flowers and wild bees aren’t important. Not at all. But why not base their importance on the value of natural diversity for its own inherent sake, and not on an attempted feeble linkage to agricultural productivity?

The authors emphasize the importance of wild flowers – even include photos in the report of beautiful wild flower stands – but overlook how difficult these stands can be to maintain. I speak from experience. About 20 years ago my wife and I naturalized a four-acre field on our farm, planting wild flowers in many areas. Twenty years later those wild flowers thrive (see the photos included in this blog). But that’s only because of many hours devoted each year to the removal of more competitive species. (The ones Mother Nature prefers are reed canarygrass, buckthorn shrubs/trees, and many noxious weeds like the invasive garlic mustard and several species of thistles.)

Wild flowers are great but not easy.

In summary this review represents a valuable contribution to the understanding of bee health in Ontario but would have benefitted if it had been reviewed, before release, by someone more familiar with field crop agriculture.

Turning the Farming Clock Back in Time Means More Expensive Food


Joe and Hazel French cutting grain in Fullarton Township near Mitchell, Ontario, circa 1950.

Agriculture has had a great run.  An era of technological innovation beginning about World War II has meant huge increases in farm productivity and food supply.

Even though the human population has grown far more in 70 years than in 100,000 years before, world food supply has increased even faster. Though the number of malnourished humans is still 790 million according to UN statistics, the percentage has dropped to 13%. It was 32% in 1970. The number of overweight or obese people is now much larger.

The real cost of growing food has plummeted too. Average families spend only about 10% of disposable income on food in many developed countries. The amount going to farmers has dropped further – down to only 1.5% of total family spending, the amount earned by January 6 each year. Most food dollars now go for processing, marketing and service rather than for farm products. About 30-40% of retail food is not even consumed by people – diverted to animal feed, compost or landfills.

This abundance is a direct result of superior agricultural technology including advanced breeding methods and genetics, more effective and less costly means of crop pest control, and better methods for soil management.

There is no technological reason why this trend cannot continue – and continue it must in parts of the world like sub-Saharan Africa and parts of Asia where hunger remains widespread and where human population growth will be largest in years ahead.

However, there are clear signs that the 70-year trend is ending.

One reason is environmental. Climate change will affect agriculture negatively in many countries, and agriculture must focus more on environmental impacts including fertilizer losses and greenhouse gas emissions.

A far bigger factor is a rejection of modern farm technology and the underlying science by an increasing portion of the consuming public. There’s a growing interest in organic foods, mostly produced using farm practices of decades past with crop yields averaging one-third lower. Demand for meat and eggs from ‘slow-growth’ farm animals and ‘free-range’ chickens may or may not be beneficial for animal welfare – but they mean lower productivity and higher costs.

Public reaction against genetically modified food (despite the strong scientific support for its safety and benefits) also means a shift back to older technology for some crops and the impeded introduction of new genetic traits for stress tolerance, pest resistance, better nutrition and less spoilage.

Where food was once promoted for what it contains, labelling for ‘does not contain’ now prevails.

Affluent developed-world consumers can afford the higher costs for foods grown using older technologies. Their willingness to pay much more for organic or non-GMO labelling shows that.

Of course, there are millions for whom higher food costs are a major burden, but their needs are often ignored in the public debate.

Farmers are adaptable. While they may question a return to older practices with lower productivity and higher costs, they respect the market. If higher market prices more than offset higher costs, then many farmers will respond.

In a blessed, large, sparsely-populated country like Canada, there should be enough food even with lower-yielding farm practices. The tragedy comes when this ‘first-world attitude’ includes aggressive efforts to prevent developing-world farmers from using new technologies for more food production – technologies to protect farm crops from the ravages of pests, climate and poor quality soils. Africa, already food deficient and facing a three billion population growth by 2100, cannot afford the luxury of old-tech-agriculture – increasingly prevalent here at home.

*Terry Daynard farms near Guelph, Ontario and is a former associate dean for agricultural research at the University of Guelph.

How Tides Canada uses its Charitable Status to Attack Agricultural Biotechnology



Tides Canada logo

Many in Canadian agriculture will recognize the Canadian Biotechnology Action Network (CBAN) as one of the country’s most vocal opponents of agricultural biotechnology. But very few know CBAN is actually a front for Tides Canada, one of Canada’s largest charities.

I have spent almost a year exploring, communicating and trying to understand and alter this relationship. I have done so quietly without public comment. The discussions have been polite and I’ve met decent people. But alas, I have been largely unsuccessful in effecting much change.

Hence, I’m writing this column. It’s time for you to know what’s going on.

Tides Canada functions mainly as an NGO brokerage service. It manages environmental and social programs/projects using money provided by others – including some from the larger US-based Tides – while providing Canadian charitable cover. Its disbursements vary by year but average about $25 million.

Most distributions by Tides Canada involve grants to other organizations. However CBAN is unique: it is not an independent organization but a “project” of Tides Canada.  CBAN is Tides Canada even though this is scarcely mentioned on the CBAN web site.

To my knowledge, CBAN represents a relatively small portion of Tides Canada cash flow. Tide Canada’s total expenditure for what it calls “Sustainable Food Systems” (also used to fund groups like Sustain Ontario) represents about 12% of total spending. The other 88% is for activities unrelated to agriculture and food.

The puzzle to me was/is why anti-biotechnology advocacy is a priority to Tides Canada.

My quest began in early 2016 with a visit to a Tides Canada director who encouraged me to document misleading statements by CBAN/Tides Canada. The CBAN web site contained many examples, and my lengthy document was submitted to the board chair after a substantial period of fact checking.

To their credit, the Tides Canada chair and board formed a special committee to consider my claims, and some wording changes were made to the CBAN web site. But other changes were not made including a phoney claim that the Golden Rice initiative spent $50 million on advertizing before 2001.

(The volunteer-based Golden Rice Humanitarian Board based in Switzerland informed me the claim is blatantly false, and I relayed this to Tides Canada. However, Tides Canada chose instead to believe a statement published by columnist Michael Pollan in the New York Times.)

Minor wording changes made as a result of my submission, and the respectful, way in which I have been treated don’t mask the fundamental problem:

Tides Canada endorses and embellishes criticisms of agricultural biotechnology including humanitarian endeavours such as Golden Rice, even when based on dubious sources – while not acknowledging that there are important benefits.

It disappoints me that, notwithstanding my representations, Tides Canada continues to hold this one-sided perspective, despite its professed interest in “sustainable food systems.”

It bothers me much more that this activity is supported by Canadian taxpayers as a charity even though much (most) of the CBAN/Tides Canada activity involves pressuring government(s).

The chair of Tides Canada insists that she has checked this carefully with the Canadian Revenue Agency; she claims as long as the activity is non-partisan, government lobbying is permitted – i.e., for far more than the 10% of expenditures for “political activity” supposedly allowed for Canadian charities.

This is wrong: Why should governments provide tax-exemptions for so-called charities that use much of the money to lobby government?

Canadian farmers work hard to produce high-quality food ingredients at ever declining real costs of production while striving to do so in increasingly sustainable ways. Biotechnology is part of that quest. It’s sad that Tides Canada is one of the obstacles farmers endure in their endeavour.

The Pluses and Minuses – What Genetically Engineered (GE) Crops Mean on Our Farm



View across a corn field on our farm

A recent visit to the Toronto office of a prominent Canadian NGO to discuss that organization’s negative, one-sided portrayal of GE farm crops got me thinking about a recent comment from Tamar Haspel, a Washington Post journalist. She asked whether those of us who talk about the positives of GE (aka, GM, or “genetically modified”) technology ever mention the negatives?

I acknowledge that supporters like me, facing an endless negative attack, are tempted to respond with the opposite; anti-GE activists emphasize the bad and we emphasize the good – while balanced analysis tends to be ignored by all.

That risk notwithstanding, this column is about balance – or more specifically, the balance as it applies to our farm

First the positives:

European corn borer and its successful control for 20 years using Bt technology is by far the biggest GE benefit on our farm. I recall, in years before Bt, the frustration of harvesting borer-infested, fallen corn plants and ears. I remember the at-harvest losses, the mouldy ears, and the risk to my arms every time I left the tractor seat to remove fallen, tangled plants from the corn picker. (Yes, I shut the picker off mostly, but I confess there were some occasions when I didn’t as it was far easier to unplug with the machine running.)

I watched with resignation during the early 1990s as many farmers in North America moved to insecticide applications for borer control, and wondered when we would be tempted or forced to do the same.

Now two decades later, I assume almost every corn plant will be standing for weeks after maturity, even as seeding rates and plant densities have increased to produce higher yields. To use those higher planting rates before Bt would have meant even more fallen plants and picker plugging.

Despite well over one billion acre-years of corn planted to Bt-borer-resistant corn in Canada and the United States, no insect resistance has evolved. Now, I am sure that genetic resistance to current Bt genes will eventually develop in European corn borer. Nature’s like that. And when that resistance comes, corn breeders and farmers will need to use new sources of gene resistance – that’s the hope – or revert to use of insecticides – the far-less-desirable default option. But 20 (and counting) years of Bt corn with no resistance apparent yet to corn borer is really a huge success.

Glyphosate-tolerant (GT) soybeans are the next most important GE crop for us. We have a problem weed called black nightshade which arrived about 20 years ago. Nightshade seeds germinate any time during the growing season; the plants grow quickly and produce dark purple berries which stain soybean seeds badly at harvest time. They can turn an otherwise top-yielding crop into something no one really wants. Fortunately, a late application of glyphosate on a GT-tolerant crop can ensure that the nightshade plants present at harvest time will have emerged too late to cause serious crop damage.

Like other farmers, we’ve learned that we must now apply other herbicides in addition to glyphosate to prevent/delay the appearance of glyphosate-tolerant weeds. But our total herbicide expenditure is still well below what would otherwise be required on this farm.

The inevitable question is: What happens when/if nightshade becomes glyphosate tolerant? That’s partly why we also use other herbicides – to reduce the odds of that happening – and why we fight hard to control nightshade in our other rotational crops. But farming’s like that: always new pest problems and an unending search for new solutions.


No-till soybeans

Glyphosate-tolerant (GT) corn, unlike its soybean equivalent, is a moderate blessing for us. We don’t rely on it as a core component of our weed-control program for corn. However, it does provide an effective means of eliminating weeds which escape control by herbicides applied at or near planting time. The benefit in controlling late-emerging weeds in corn is not for the current crop but to prevent weeds from producing seeds to infest the next year’s crop.  We have cut back usage of atrazine and other herbicides for weed control in corn – another benefit – knowing that we have an effective back-up plan with GE technology.

Those benefits are partially offset by the need to remove “volunteer” GT corn plants growing in GT soybeans the following year. Fortunately, that’s not difficult or expensive to do. So far the economic and agronomic benefit for GT corn outweighs the added cost, but it is less substantial than with soybeans.

Some negatives:

Bt resistance to corn rootworm is probably of no current benefit on our farm. Indeed, it is a negative in that most GE corn hybrids we buy contain that trait and we pay for it through a higher seed price – I don’t think that much but it’s still a cost. The selection of hybrids containing Bt resistance for corn borer but not rootworm is limited and often does not include those with the highest performance in other traits – especially yield potential.

Corn rootworm can definitely be a problem in Ontario. During the 1970s, before soybeans became an adapted crop in most of the province, many farmers like us grew continuous, monoculture corn which fostered corn rootworm expansion. That necessitated the use of soil-applied granular insecticides. The introduction of crop rotations like corn-soybeans and corn-soybeans-wheat solved the rootworm problem in Ontario during the 1980s, well before the advent of Bt corn. But corn rootworm has evolved to tolerate corn-soybean rotations in parts of the US Midwest – and that may inevitably spread to Ontario. Maybe Bt rootworm resistance will benefit us in the future, but not now.

A bigger negative is overall seed cost:  GE seed costs more and that’s a major reason why some farmers grow non-GE corn and soybeans. For us, that cost is more than counterbalanced by higher crop yields and reduced herbicide costs.

Some critics say the need to repurchase seed every year is a negative with GE crops. That’s not true for corn since its hybrid nature means that farmers cannot replant their own harvested seed and expect to get plants of the same yield potential the following year. It’s been that way since before 1950 when virtually all Canadian corn became hybrid. Nothing changed when GE corn was introduced many decades later.

But soybeans are not hybrid and many farmers have historically kept their own seed for planting the following year. They can’t do this with herbicide-tolerant GE soybeans because they must sign a commitment not to keep seed for replanting when they purchase the original seed. If they want to reuse their own seed, they can grow non-GE varieties of which there are many.

Personally, I do not see the need to purchase seed every year as being negative to my long-term well-being as a farmer. The profits received by seed suppliers mean increased research to produce more competitive, higher-yielding, higher-quality varieties. The burst in productivity now being experienced with canola yields in Western Canada is the direct result of increased competition and more crop breeding – caused by the combination of patented GE technology and new canola hybrids.

The development of glyphosate-tolerant weeds is widely cited as a negative with GE crops, and it is. We have none yet on our farm, but know their arrival is inevitable. However, we balance that negative against the positive – that there is a decreased likelihood of weeds developing tolerance to other herbicides, thanks to glyphosate usage. The first herbicide-tolerant weeds appeared on our farm about 40 years ago. Weed tolerance to herbicides did not begin with GE crops and glyphosate usage.

I’ll close this column with a brief listing of potential benefits with GE crops which we can’t realize because those crops don’t yet exist.


Black nightshade weed growing in white bean field

For 35 years we grew white beans (also known as navy beans and pea beans). White beans were very profitable but tricky to grow, and the increasing difficulty of managing nightshade in white beans ultimately caused us to stop producing them. In 2015, the last year, our herbicide bill for white beans was $93/acre and we still had more nightshade than I liked. Now if there were glyphosate-tolerant white beans….

Wheat is another crop we’ve grown for more than 30 years. In recent years it has required applications of fungicide – usually more than one per year. If not controlled, Fusarium infection will cause poisonous mycotoxins to form in wheat kernels. About 15 years or so ago, Syngenta had a research program designed to control Fusarium using GE technology. But strong opposition to GE wheat technology from many sources caused Syngenta to terminate the program. That’s so unfortunate – unless, of course, you profit by selling fungicides.

So what are the conclusions?

One conclusion is that the balance between benefits and costs/risks with GE technology is very farm specific and technology specific. It’s highly dependent on the needs of individual crops and the prevalence of crop pests. Second, benefit-cost balances are not static and change with changes in pests, plant genetic improvement, cropping situations and market conditions. And third, those who attempt to make sweeping generalized conclusions about GE technologies without understanding the on-farm complexities mostly lack any real understanding of what’s going on.

*Terry Daynard and his wife, Dot, grain farm near Guelph, Ontario.


Report by the Environmental Commissioner of Ontario on Soil Health Badly Weakened by Inaccuracies, Omissions, Superficiality and another Agenda


There is much to applaud about a new report by the Environmental Commissioner of Ontario (ECO) called “Putting Soil Health First.” (The report is available here; a brief summary by John Greig can be found here.)

The report emphasizes the need to improve soil quality and reverse a long-term downward trend in soil organic matter levels in Ontario soils. The writer of the report demonstrates a good understanding of soil biology and its relationship to agronomic performance, and rightly criticizes an agricultural industry which has not placed sufficient priority on maintenance and improvement of soil quality. The report also acknowledges the success of this industry in producing an ever-increasing abundance of food at a declining real cost to consumers. Ontario farmers and others interested in this subject should take the half hour or so required for a read.

At the same time, I have major unease with the report. Too often, it seems as if the commissioner and/or her writers have used the issue of soil quality for another agenda: to attack non-organic agricultural practices which have little effect on soil quality and which in fact can and do make a positive contribution to soil organic matter enhancement. I’ll briefly highlight some examples below.

The report contains a strong condemnation of synthetic pesticides and fertilizer, stating that they are partially responsible for declines in soil organic matter while providing scant evidence that this is true. The report contains one small section called “How the Inappropriate or Over Use of Synthetic Inputs Can Impair the Natural System,” but even that section seems to rely excessively on anecdotal information and opinions, suggesting that temporal impairment of microbial activity at time of application means long-term, measurable changes in soil organic content. In addition, the report totally ignores good logic and evidence for the reverse – for example, the increase in crop organic matter production including additions to the soil stimulated by good fertility and by the control of leaf/plant-killing diseases and insects.

The report rightly points out how tillage encourages soil organic matter oxidation, but ignores the benefit of pesticides (herbicides) in reducing/eliminating the need for tillage. This is a huge oversight in my view.

The report seems also to perpetuate the myth than better soil structure means fewer weeds – hence, less need for pesticides. Crop plants grow better in better structured soils, it’s true, but so too do many weeds. Indeed, the main reason why these plants are serious “weeds” is that they prosper in the same ecological niche as the crops which they infest.

The commissioner also makes the strange suggestion that climate change will increase the prevalence of herbicide-resistant weeds. (The reference cited by the commissioner in support of this statement makes no such claim.)

Perhaps to place fertilizers in a negative light, the report provides an extensive report of one farm in North Dakota which reports good yields with minimal fertilizer usage. There is no mention of the decades of extensive publicly-funded research which has been done on soil fertility needs in Ontario and adjacent states. Further, discussion with organic farmers in Ontario reveals that the provision of an adequate supply of P fertilizer – and in some cases N too, for example in meeting the needs of winter wheat in May-June – represents one of their biggest agronomic challenges.

The report rightly condemns the unsustainably high loss of phosphate from farm soils and the importance of minimizing surface water runoff. But there is no mention of the significance of losses through tile drainage, nor of informed suggestions (albeit controversial) that this loss may be enhanced by deep, well-developed soil pores associated with no tillage.

The report condemns the use of summer fallowing in Ontario – which begs the question: does summer fallowing actually exist in Ontario (notwithstanding those instances where excessive spring rainfall prevents crop planting)?

The report rightly emphasizes the linkage between animal agriculture – or more specifically, ruminant animal agriculture – and perennial forage production. But it  dodges  the reality that this may also mean increased greenhouse gas emissions (from rumen methane emissions) to offset, at least in part, the resulting increase in soil organic matter associated with perennial forage production. The report also makes two really strange statements about animal agriculture – one being that livestock farms are not closely connected to crop production. (One wonders whether the commissioner or her writers are aware of Ontario’s “nutrient management” requirements for livestock farms.)  The other is the implication that manure storage – with associated emissions of methane – is not needed when farmers apply manure to their own fields. This seems to ignore the evils of applying manure to soil in winter and ministerial guidelines on lengths of manure storage required (sometimes for a year or more).

I have always been of the opinion that while composting is beneficial in reducing manure volume/weight and in producing stable organic matter, it also represents a loss of about half of the carbon content of the original organic material; organic matter converted into carbon dioxide in the compost pile would otherwise be used to feed soil organisms if applied directly to soil. The report makes a feeble attempt to argue that composting is better but its scientific support and rationale for saying so is very limited. The argument that composting reduces nutrient loss in the field (instead, the nutrients leach under the compost pile!) is equally flimsy.

The report features one organic farm in New York State which produces yields of 200 bu/acre of corn and obviously does a good job. (It does not state whether this is the harvested production from one year or two years of cropping; organic farmers sometimes don’t harvest a previous year’s legume forage to maximize soil N supply for the corn crop to follow.) However, notably missing is a reference to extensive multi-farm data (crop insurance in Ontario; USDA in the US) showing that organic crops, on average, yield about 2/3 of their non-organic counterpart. On average, it take 3 acres of organic land to produce as much as 2 acres of non, and that has obvious implications on the total amount of land needed – not to mention the cost to consumers, and the environmental cost – to meet Ontario’s food needs.

The report features the Belan farm near Inwood, and with good reason. I too am a fan of the practices of this innovative farm and their 25 years of no tillage. The report notes the Belan claim that their soil organic matter has increased from 2 to 5% because of no tillage, but also notes that this is only for the upper 15 cm of soil. I drew that conclusion once myself – that no till was having a huge effect on soil organic matter in my plots at Elora. But then Dr. Tony Vyn and Dr. Bev Kay measured soil organic matter at deeper depths and found the reverse down there. No tillage generally means a change in OM distribution rather than an increase in soil OM per se in Ontario and eastern Canada – at least in most test results (as an exception, Dr. Laura Van Eerd and colleagues have measured higher OM in no-till soils to depth, but only in certain crop rotations, at Ridgetown.) With respect to the Belan farm data, the report says “the reader should note that the ECO is not suggesting that the Belan’s situation should be taken as definitive from a soil-carbon sequestration perspective.” But then the report goes on to do the exact opposite with some extensive calculations for all of Ontario based on one farm’s numbers. There is certainly no qualification in the summary statement: “the Belans have increased the carbon levels in their soils by three per cent, which means that they have sequestered about 48,000 tonnes of CO2.” Once again, no slam is intended by me to the Belans. This criticism is about what the commissioner did with their information.

Indeed, almost totally missing in this report is recognition of the extensive research which has been done by public researchers at the University of Guelph (including Ridgetown) and Agriculture and Agri-Food Canada. The emphasis is instead on anecdotal reports from a few individual farms. The commissioner is very critical of actions by the Ontario Ministry of Agriculture, Food and Rural Affairs with respect to soil quality, but does not appear to be aware of most of what the ministry and its staff actually do – including core funding of soil management research at Guelph and Ridgetown. I am also bothered by the emphasis on popular press reports in the reference material, with relatively few references to formal research publications. There are also many places where the commissioner seems to draw unqualified conclusions based on a single reference (often anecdotal).

Finally, I am puzzled with the occasional references in the report suggesting that better soil stewardship was practiced in days past. Statements to the effect that earlier farmers did not leave soil bare in winter are simply false. In fact, one of the first traditional operations immediately after wheat or spring-grain harvest was usually mold-board plowing– and condemned was the farmer who left any crop residue showing on the soil surface after plowing was completed.

The same applies for crop rotations. Forty years ago, many Ontario farmers grew only corn, and 160 years ago it was continuous wheat. Even my father in the 1950s grew only two crops in rotation – perennial forages and spring grain. Soil quality might benefit from more crops in the rotation, or it might not:it depends on the crops. Many alternative crops don’t produce a lot of crop residues and, hence, soil organic matter – e.g., beans, vegetable crops. We’ve already talked about perennial forages, an excellent addition to your crop rotation – IF you have a market.

My list of faults with the commissioner’s report has not been exhausted. But I expect that my reader’s attention span has. So I’ll close here.“Putting Soil Health First” is a useful report, but it could have been so much better it the commissioner and/or her writers had focused on soil health alone and avoided the temptation to promote another agenda. Sadly, I’ll now be reading with skepticism any other reports from the ECO. Will they be equally distorted? Will they too have another unstated agenda?