The ECO agrees with MOE’s determination that it would not be in the public interest for the Ontario government to duplicate the federal approval process for GE alfalfa. The responsible federal agencies assessed the environmental safety of the GE alfalfa plant – including the potential for genetic contamination and potential impacts on biodiversity – and concluded that the plant poses a “minimal apparent risk” to the environment. Provincial ministries should be able to rely on the review process of one of its federal counterparts.

However, the applicants raised several valid issues that clearly fall outside the scope of the narrow federal safety assessment. Issues related to sustainable and organic agriculture, increased herbicide use, and related social and economic effects play no role in the federal approval process for GE crops. These important environmental and socio-economic concerns should not be ignored by the Ontario government. The applicants also voiced concerns regarding the lack of transparency and public participation in the federal approval process. The ECO is disappointed that MOE failed to address any of these issues in its response to the application.

In theory, Ontario’s EAA has great potential to encourage informed, responsible and sustainable public planning; in practice, however, the government’s increasingly narrow application of the Act significantly undermines this potential. The ECO has long called for the Ontario government to revive the original purpose of the EAA: the betterment of the people of Ontario. Although using the EAA to regulate the distribution and sale of GE alfalfa would be a novel application of the Act, consideration of the environmental, social and economic issues raised by the applicants through an EA would be in line with the original purpose and intent of the EAA. Such a process would provide a measure of transparency and an opportunity for public participation, something that is severely lacking in the federal process. Input from the public and the province’s farmers could help ensure that the decision to allow such activities is based on the best possible information.

Finally, the ECO believes that the cultivation of GE crops in general raises important environmental issues that warrant attention; for example, the ECO previously expressed reservations about glyphosate-resistant GE crops in our 2011/2012 Annual Report. The ECO encourages the Ontario government to play a more active role in regulating the sale and use of GE crops in the province, rather than simply following federal decisions that may not encompass provincial environmental goals and interests.