Preface
Sometimes in life you have to be careful what you ask for. Ontario farm organizations and the farmers they represent asked for nutrient management legislation that was reasonable, fair and just, and was the same across this province. What has been proposed has the potential to change the face of agriculture in this province. I still thought we were living in the “common sense” revolution where the “red tape” commission made it easier to do business with government.
What we have here makes little sense in certain sections and increases the red tape. In Lambton we held 2 meetings on draft 2 regulations. One, an information session which was attended by 275 farmers, and one that was hosted by the LFA which was a feedback session where farmers could express their thoughts on the proposed regulations. This was attended by 110 farmers.
The presentation I am about to give is a summation in point form of their thoughts. I will give some general overall comments as was heard from the group and then touch on specifics.
General overall comments
- Nothing in the United States of America is mandated until the money is there.
- We are expected to agree to regulations that are extremely costly without any known funding protocol. It reduces our world competitiveness.
- In certain sections of the regulations the same cannot apply for the complete province because of climate, soil type, topography.
- As it stands now good farm management and common sense is superseded by regulations. Example no-till and incorporation.
- Some of the very reasons for the existence of these regulations was to control where large farms build and how they handled their waste but the regulations have the potential to expedite more large operations in that it makes no economic sense for small farm operations and farmers near retirement to spend the money.
We currently have laws in place to prosecute polluters. If we are not polluting why is this being done.
Farmers won’t know their true costs until a nutrient management plan is done and by then regulations will be in place
Trespassers on farm properties will have even more reason to cross farms on snowmobiles and 4-wheelers now that the countryside has manicured buffer zones along ditch banks and waterways.
If and when these regulations are proclaimed municipalities must not have the power to supersede them (probably will take a court case to test this one)
The act does not look at alternatives to deal with the problems. (Ex – the use of wetlands to filter our ground water.)
A young producer in our county does nutrient management plans. He did a plan for his own operation, which is a small beef feedlot operation. Using the NMA program to determine capacity required for both dry storage and liquid runoff from his barnyard. His final calculations determined his cost to be about $3000/animal to comply.how many producers can stand those costs? This is just one of many examples.
Specific concerns
- Land application standards
What is a municipal well (ex more than 5 users/well), concerns how to identify these and why 2 year capture zone? (case here where science needs to catch up with the regulations, 2 year capture zone has not been determined) - Oil and gas wells should not be in these regulations. In Lambton we have many of these (sometimes on one farm) and staying back from these makes it very impractical.
- What setback is required for hickenbottoms?
- Need science-based proof spreading on frozen ground is bad.
- High trajectory irrigation guns can cause some instances of odour problems but the good points relating to no soil compaction, uniform application rates, better control of the correct amount being applied and applied at a time when crops can start to make good use of the nutrients out weigh the disadvantages.
It’s a judgement call and farmers need that option in cases where weather conditions do not allow for heavy application equipment and manure pits are full. Liquid manure does not pile very well. Some farmers also use these for water irrigation.
Winter spreading
- Early spring application of manure on clay soils causes compaction and reduced crop yields.
- Winter spreading allows spreading on a larger acreage, over a longer time period and odour problems are of less concern. Good farm management, weather and ground conditions and topography of the ground should dictate winter spreading not dates on the calendar.
- This is a typical case where one size does not fit all for the province. It’s hard to legislate good farm management.
Concern about spreading nitrogen on winter wheat while ground is still frozen or spring seeding of cereal crops on frost. Both farm management practices lead to improved yields.again dates should not determine application timing.
- References to living crop (ex wheat, forages), what about corn stalks. They soak up a lot of nutrients and filter them.
- Need a contigency plan for winter (ex ½ the rate and 4x the distance from streams)
Tile drains
- Visible inspection when applying liquid manure a given however the problem often occurs after a severe storm sometimes days later.
- Concern expressed about road salt entering municipal drains
- Not very practical to put a monitoring system on tile drains.
- Blocking tiles will cause severe head pressure and blow tiles apart and cause even more problems
Odour considerations
- Supposed to be a nutrient management act not an odour act.what does odour have to do with water quality?
- Odour needs to be part of normal farm practice
- Not practical to incorporate manure in 6 hours
- No till farmers don’t have the ability to inject manure.
- Wind should have no bearing legally.
Temporary in field storage
- Composting has not been addressed here, big problem for organic producers.
- Concern about the amount of non-productive record keeping required
Existing storages
- Existing studies done by OMB shows no problem with existing storages
- Earthen manure lagoons still allowed in Lambton but engineers won’t sign their name to them (Ontario gov’t allows clean harbours to accept untreated toxic waste from the world to be stored in Lambton soil)
Buffer strips
- Good management practice if soil topography requires it.
- Non productive land can’t even harvest for hay
- Amounts to a lot of land for many producers.
Record keeping, training & licensing
A lot of non-productive time and effort spend either in your office or at training sessions that farmers have being doing as part of good farm management. Most farmers only have time to attend workshops that can be productive to their business.
Summation
As I said in the beginning these regulations have the potential as they exist to change the face of agriculture in this province. Most producers can ill afford to have more non productive debt placed on them during a time when they already lag behind in govt support compared to competing farmers in the world. Ontario farmers and farm organizations time after time have proven themselves as good stewards of the land and the environment through the many programs they have been proactive in developing (ex Ont environmental farm plan).
I do not believe officials who compiled these regulations have any idea the cost or the impact they will have to Ontario agriculture nor do i believe any organization can accurately predict the cost until it is actually done because agriculture is so diverse in this province.
My take home message today is there has to be some dramatic changes to these regulations and society must be prepared to shoulder the cost.
Thank you!
~Jim Duffy~