December 22, 2017
The Honourable Rochelle Squires
Minister of Sustainable Development
344 Legislative Building, 450 Broadway
Winnipeg, MB R3C 0V8
Dear Ms. Squires:
RE: Response to the Made-in-Manitoba Climate and Green Plan
Hog Watch Manitoba is a coalition of farmers, environmentalists, animal welfare supporters and concerned members of the public who are promoting a sustainable hog industry in Manitoba. We appreciate the opportunity to offer feedback on the Made-in-Manitoba Climate and Green Plan.
We commend the government for creating this plan and particularly for addressing forthrightly the reality of climate change and the human actions that have caused it. We support wholeheartedly the ambitious vision to be the cleanest, greenest, most climate resilient province in Canada. We also support strongly the concept of building in indicators of success. However, the success of this plan will be based on the development and implementation of measurable targets with annual public reporting on outcomes in every sector. We urge the government to ensure that those measurable targets and the requirement for annual reporting on the results of actions to decrease emissions( both GHG and nutrient pollutants) are in place by the end of 2018 in order to facilitate meaningful change. Transparency and accountability are essential if this plan is to become a framework for real change.
We are concerned about the exclusion of agriculture from many emission reduction requirements for the very reason that agriculture is the backbone of Manitoba’s economy and if we want it to remain so, we need to build in sustainability. Consumers worldwide are becoming much more concerned about sustainable practices across many different fronts. Attention to sustainable practices is commonplace now on many labelling initiatives. We are not doing the Manitoba agriculture sector any favours by not ensuring that they move quickly towards sustainable practices that reduce carbon emissions, like organic methods. Organic growing mitigates climate change, reduces energy use and builds public trust (here and abroad) in Canadian food. Organic agriculture in Canada drives clean economic growth and provides a climate change mitigation strategy. Organic agriculture contributes to a low carbon economy by enhancing soil carbon sequestration and prohibiting the use of harmful, energy-intensive nitrogen fertilizers, which are responsible for over 70% of Canada’s total nitrous oxide greenhouse gas emissions.
As part of our Made in Manitoba Climate and Green Plan we need to reduce the deforestation for spread acres that is taking place in Manitoba, especially in Hanover and La Broquerie. The practice of protecting undisturbed forest soils for future generations is supported by current scientific evidence, which has found that the ectomycorrhizal fungi of the forest can absorb 30% more human created carbon dioxide under low nitrogen conditions than grassland and agricultural soils dominated by arbuscular fungi. The roots of forest plants are closely associated with their ectomycorrhizal fungi that can deliver extra atmospheric carbon dioxide directly to the plant, causing a 30% increase in growth—this is termed the ‘fertilization effect’. In a recent study into the fertilization effect, the research team analysed 83 carbon dioxide fertilization experiments, which demonstrated that a plant’s ability to take advantage of extra CO2 depended on whether the roots were associated with ectomycorrhizal or arbuscular fungi. The forest-type ectomycorrhizal won hands down every time with an extra 30% plant growth. The arbuscular fungi in the agricultural/grassland was not able to take advantage of higher carbon dioxide levels at all. (Terrer, et al., 2016)
We are strongly opposed to the use of Water Quality Trading as a nutrient reduction strategy. It essentially allows polluters to opt out of installing pollution reduction technologies. This system may have appeal from a theoretical perspective but putting it into actual practice is fraught with many difficulties, not the least of which is that we currently do not have timely and accurate measures of nutrient pollution from many different sources. If one considers the ongoing arguments about how much phosphorus pollution into Lake Winnipeg is coming from the city of Winnipeg versus agriculture in Manitoba, it would seem irresponsible to make assumptions about either for the purposes of Water Quality Trading. Considering the vital importance of having clean, safe water for drinking, recreation and fishing, we cannot afford to do anything that would not move towards that goal now and in the future. Market-based, fiscal, and/or voluntary non-regulatory initiatives, wherein expansion and growth are the actual and paramount objectives, ensure the proliferation of environmentally unsustainable developments, while propagating the illusion of environmental protection.
As a general comment, the Made in Manitoba Climate and Green Plan (MMCGP) is conceptually flawed in that it identifies Nature as one of ‘four pillars’ of sustainable development. In fact, Nature (as opposed to knowledge, education, planning, and foresight identified in the MMGP) is the overall foundation not only of our very socio-economic existence, but also of any ‘plan’ whose purported objective is to achieve a ‘sustainable future’.
Among other things, this flaw taints the meaning of ‘sustainability’ implicitly underlying the MMCGP, a meaning whose emphasis is on economic growth (or what is described as ‘a more prosperous future’). In turn, this leads to consideration of ‘Nature’ as a reified entity that is described in the MMGP as ‘Natural Capital’. From such a perspective, ‘Nature’ is primarily a commodifiable resource, similar to human-made capital, which is to be utilized ‘economically’, rather than being viewed as a complex multi-layered system of organically integrated interrelationships characterized by a multiplicity of interactive feedbacks which, in the last analysis, ultimately provides the limiting context within which any economic activity proceeds.
As noted in the MMCGP, First Nations people have traditionally recognized this and hold “true to a seven generation philosophy of living at one with their surroundings” (p.6). While we commend the MMCGP for acknowledging the importance of traditional knowledge to any discussion of ‘sustainability,’ we find it curious that, in the development of the MMCGP, the government did not consult with indigenous peoples. This suggests that the government is merely paying lip service to role First Nations play in the process.
Contrary to marginalizing this role, what is legally required is meaningful consultation and accommodation since, as the government has recognized, any development policies, activities, or decisions contemplated may have a negative impact on aboriginal or treaty rights guaranteed by the Constitution Act of 1982. At a practical level, we submit that such consultation and accommodation must be undertaken in a separate process, one that is enjoined prior to the triggering of any provincial statutory-based approval processes.
A further indication of the marginalization of First Nations traditional knowledge is contained in the MMCGP’s comments (at p. 6) relating to farmers, who “have extensive experience and knowledge of the land and climate.” The suggestion is that this knowledge and experience is equivalent, indeed superior, to First Nations traditional knowledge. This suggestion is implicit in the statement that while traditional knowledge “can be a powerful foundation upon which to build the next generation of sustainable development actions,” bringing farmers’ “knowledge to the forefront to help address climate change, water and land use is smart and useful.” (p. 6).
Such a view is predicated on the false (but widely held) belief that farmers are and have been ‘good stewards of the earth.’ In fact, as has been repeatedly shown in the decades since the Canadian Senate’s Soils at Risk was issued, considerations of ‘security and profitability’ have always trumped ‘environmental stewardship’ activities by farmers, habitat loss (now accelerated by the increasing of farm size and the industrialization of agricultural production) being the most obvious example. The point is that the ‘knowledge base’ of farmers is qualitatively different from that of First Nations people, both conceptually and practically; the latter is sustainable, the former is not.
This notwithstanding, the MMCGP is excessively generous to the agricultural sector. While agriculture is identified (p. 22) as the second largest Greenhouse Gas (GHG) emitter, accounting for 32% of Manitoba’s emissions — exclusive of fuel use emissions, it is to be exempted from many of the MMGP’s emission reduction initiatives, notably the carbon tax. The stated rationale for this is that various components of the agricultural sector are price-takers and cannot recapture the carbon tax in the sale of produce. (p.17) In the hog sector, it is useful to recall that it was the Filmon government’s removal of the single desk which eliminated the capacity for hog producers to be price-setters, or at least to negotiate prices for hogs on a level playing field.
In this context, we would ask the following. What is the estimated amount of projected income losses for hog producers from the carbon tax? Stated alternatively, what is the value to the hog industry of a carbon tax exemption, which is actually a ‘tax-expenditure’ subsidy, and what is the projected loss in reduction of GHGs that will result from this exemption?
In addition to these exemptions, the agricultural sector is to receive additional taxpayer-funded support through such things as an ALUS-type ecological goods and services program, the developing of a Centre for Sustainable Agriculture, the supporting of research and commercialization of technologies, supporting on-farm BMPs, and so on (p. 23). The stated rationale for such generosity is that agriculture is a “mainstay of Manitoba’s economy” and that “addressing land and water use together can help harness natural opportunities for managing irrigation, prospering through climate change, sequestering carbon on agricultural land, and increasing yields.” In other words, the intent is to expand agricultural output, leaving the question of “reducing agricultural emissions” to sometime in the unspecified future “through a range of other policies and actions that will be developed with the farming community and agricultural sector.” (p. 18)
With respect to the hog industry, specifically the Intensive Livestock Operation (ILO) sector of that industry, we submit that there are a number of initiatives that can be immediately implemented by the government that will make a significant contribution to achieving the stated goals of the MMCGP. Many of these initiatives relate to the problem of phosphorous overloading on soils, and the consequent transport of P2O5 into waterbodies with the resultant degradation of water resources such as Lake Winnipeg. The underlying principle is that the prevention of harm is, from the perspective of sustainability, always preferable to mitigation.
The issue of phosphorus overloading of soils can be defined most simply in the following way. All livestock production units generate manure. In traditional agriculture systems, the livestock/land base ratio is sufficiently small to permit animal waste to be completely utilized as a crop fertilizer. Indeed, in traditional agricultural livestock operations, the amount of manure generated is generally insufficient to cover the requirements of available cropland. Manure application in such operations tends to be consistent with agronomic rates, i.e. applied in amounts consistent with what crops can use. Here, manure is a soil amendment. If applied at agronomic rates, manure serves to replenish soil fertility, which is required for any system of sustainable crop production.
The situation is fundamentally different with hog ILOs. Here, the livestock/land base ratio is so large as to prevent manure from being completely utilized as a crop fertilizer. Indeed, the volume of manure generated presents industrial livestock producers with a waste disposal problem, arguably a toxic waste disposal problem. Consequently, these producers systematically over-apply manure relative to crop utilization requirements. Livestock waste constituents (such as P205 ) which are applied in excess of agronomic rates accumulate in the soil and eventually become available for transport to surface waterways, with deleterious consequences.
The consensus in the scientific community is that the level at which phosphorous’ availability for transport increases exponentially is reached when the Olsen soil test for P205 approaches 60ppm (276lbs of P205/acre). At this level, given that the highest P205 crop removal rate (alfalfa) in Manitoba is 69lbs/acre, it is obvious that any further application of manure has absolutely no practical utility as fertilizer and, from an agro-ecological and regulatory perspective, must be considered to be a pure waste product.
In heavy industry, utilization of the environment for the disposal of waste has long been recognized as a polluting practice, one that results in the degradation of environmental resources, a degradation that is antithetical to the concept of ‘sustainability’. Furthermore, it has been long recognized that such practice, if permitted, conveys a considerable economic benefit to the polluter, reducing (in most cases, substantially) the ledger costs of production. In other words, it constitutes an environmental subsidy achieved through cost shifting/cost avoidance. North American jurisdictions have addressed this problem through the development and aggressive enforcement of an extensive regulatory regime, from which the agriculture sector has traditionally been excluded.
As it turns out, there are a number of ways to address the phosphorous problem ingredient in ILO hog production and thereby facilitate the MMCGP’s objective of “removing environmentally harmful subsidies” (p.30) enjoyed by the hog industry.
First, one can attempt to address the problem by treating liquid hog manure through such means as anaerobic digestion, a process that concentrates and converts phosphorous into a form that is more readily transportable to phosphorous deficient areas. The current government has recently rejected this option.
The second approach involves considering manure generated phosphorous as a regulated nutrient and placing restrictions on the amount (net of crop removal) deposited on spread fields. This is the approach informing the ‘phosphorous regulation’ specified in Manitoba’s current LMMMR.
The difficulty with the ppm ranges specified in this regulation is that, when considered in relation to crop utilization rates, the application of stunning amounts of P205 are permitted. Thus, the initial regulatory threshold (60ppm) translates to 276 lbs/acre of P205 and the upper threshold (180ppm) translates to 828 lbs/acre of P205. The average P205 crop removal rate in Manitoba is 20.47 lbs/acre. By analogy, establishing the phosphorous regulation at these levels is akin to placing a speed limit on provincial highways where none existed before, but setting that limit at 200kms/hour.
Objectively, the effect of this regulation is to permit a rapid build-up of phosphorous in soils, a build-up that (even in the absence of further manure application) can take years, if not decades, to reduce. For example, research by Martin Entz (University of Manitoba) has shown that, where no additional fertilizer was applied, it took 11 years to reduce soil test levels from 50 lbs/acre soil test phosphorous to 11 lbs/acre (i.e. a 39 lbs/acre reduction) in the spread lands he analyzed (alfalfa, flax, and wheat rotation). Such outcomes constitute a substantial environmental liability – an environmental debt – thrust upon future generations of Manitobans. Just as the current government has argued that the province’s fiscal debt places an unfair burden on future generations, we submit that this environmental debt places an equally unfair burden on these generations.
Finally, within the context of the phosphorous regulation, one can specify the number of spread acres that a hog ILO operation is required to have available as part of licensing and permit requirements. This is the approach exercised by Technical Review Committees who evaluate spread land requirements by relying on Manitoba Agriculture’s Soil Fertility Guide which considers 15ppm (69 lbs/acre of P205) to be a ‘medium’ to ‘high’ level, and 20ppm (92 lbs/acre of P205) to be ‘very high’. The difficulty here is that there is little in the way of long-term guarantee that access to sufficient spread lands will be available to the hog ILO operator over the life of the operation after permits have been issued.
We propose three initiatives that will resolve these difficulties, and further the achievement of the MMCGP’s vision of making the province “Canada’s cleanest, greenest and most climate resilient province” (at p.3).
First, the phosphorous regulation must be amended to limit manure application on all fields to the agronomic rate, — i.e. 1 x crop removal rate — with the upper limit set at an Olson soil test of 15ppm (69lbs/acre of P205), rather than 180 ppm (828lbs/acre of P205) for all new and expanding livestock operations, in order to ensure that overloading of soils is prevented.
Secondly, we submit that there is sufficient scientific evidence to establish a 5 acre/Animal Unit requirement as the reasonable (and green) standard for determining the amount of spread lands necessary for all livestock operations.
Finally, the long-term access to spread field acreage problem can be resolved by requiring ownership or possession of signed, legally binding long-term leases (minimally, 20 years in length – which is the average design life of Hog ILO facilities) as a condition that must be met by permit applicants at the time of application.
Further to these initiatives, we submit that synthetic covers for lagoon storages must be required of all ILO hog operations. Such covers are necessary to reduce the problem of the exacerbated imbalance of nitrogen/phosphorous ratios in stored liquid hog manure resulting from nitrogen volatization, which is estimated to be about 30% in uncovered storages. In addition to reducing odor, synthetic covers can also reduce methane emissions and permit the use methane produced by hog ILOs to generate green sources of heat, as recommended by the Clean Environment Commission CEC).
At page 53, the MMCGP provides a list of possible indicators relating to the “maintainence and enhancement of our healthy agro-ecosystem.”
Given that the CEC has documented severe phosphorous overloading of hog ILO spread lands in Hanover and LaBroquerie (as well as the rest of the Red River Valley Special Management Area, removed by Bill 24), the premise that our agro-ecosystem is “healthy” is false. As well, the indicators listed do not actually speak to and/or give misleading impressions about the status of this ‘health.’
The first indicator, “production of agriculture products in concert with ecological goods and services,” is misleading. All agricultural production derives benefit from the ecosystems in which it takes place, regardless of how impaired those systems are. Apparently, the quantifiable dimension of this indicator is increased output of “market goods produced” (p. 23). Leaving aside the fact that this reproduces the reified view of Nature as a commodifiable resource, this indicator simply measures changes in output. Unless supplemented with precise eco-system inventory baseline data collected on a farm-by-basis to which changes to this baseline can be compared, this indicator tells us nothing about agro-ecological health. Similar observations apply to the second indicator, “hectares of natural capital.”
The third indicator, the “number and type of BMP implemented by watershed” is also misleading, at best. The basic problem here, as the George Morris Center reported to the CEC, is that the concrete effectiveness of BMPs has yet to be demonstrated in those jurisdictions where producers have adopted them. Thus, by analogy, using the number and type of BMPs as an indicator of agro-ecosystem health in a watershed is about as valid as using the number of Lotto Max tickets sold as an indicator of watershed wealth. The same observation applies to the fifth indicator, the number of “environmental farm plans created or renewed.”
The content of the fourth indicator, “soil health,” is completely unspecified. Consequently, as it stands, it is a meaningless indicator. We submit that one way to concretize this indicator in relation to the issue of phosphorous overloading, particularly by hog ILO operations, is to require farm-by-farm (as opposed to regional and/or watershed) phosphorous budgets, developed by using baseline soil (and water quality) test results, which establishes enforceable parameters within which an operation is permitted to operate. Annual follow-up soil (and water quality) testing can then be monitored and compared to the baseline in order that inferences can be drawn.
As noted at p. 35 of the MMCGP, there is an “interconnection between land and water activities.” While generally true in relation to agricultural production in general, it of particular importance in hog ILO livestock production, a fact underlined by the negative impacts on the quality of surface and groundwater resources (such as Lake Winnipeg) that have attended the industry’s expansion in Manitoba. Among other things, this experience has shown the need to take concrete steps to prevent nutrient loading (notably, phosphorous) to surface waters and nutrient contamination (notably, nitrogen) of groundwater supplies.
Earlier, we discussed the initiatives that, we submit, are minimally necessary to address the transport of phosphorous from hog ILO spread lands to surface waters. We turn now to the matter of preventing groundwater contamination, notably from nitrogen.
First, we submit that the MMCGP must include a government undertaking to prohibit the approval of any hog ILO whose proposed location is in any area identified as “sensitive” or “groundwater sensitive”.
Secondly, we submit that the government require the collection of baseline data on groundwater quality for submission as part of a hog ILO application in the assessment process, prior to the granting of any local or provincial approvals.
Third, we submit that the government require groundwater water quality monitoring within a 2-mile radius of any hog ILO development, whose results are to be compared with the baseline data on an ongoing (e.g., weekly) basis to detect in a timely fashion nitrogen migration.
Finally, we submit that a proper (and comprehensive) decommissioning plan, along with an environmental performance bond sufficient to implement such plans (and to rectify any groundwater contamination resulting from the operation/decommissioning of the development), be required of all hog ILO applications prior to the granting of any local or provincial approvals. Such plans must provide for the monitoring of nitrogen migration during and following the lagoon decommissioning process.
In our view, these measures are minimally necessary to achieve the MMCGP’s objective of properly protecting and managing our groundwater resources sustainably.
We strongly support the principle of “no net loss” in regards to wetlands. As wetlands are like nature’s kidneys we cannot afford to lose any more given that we have already lost 70 % of wetlands across the Prairies. In the face of increasing flood and drought threats we urge the government to develop restoration plans for a percentage of our lost wetlands as well as programs to ensure no further loss of wetland functions. John Pomeroy’s 2014 study of wetland loss concluded that drainage of wetlands over the last half century had increased the peak flow from the 2011 Assiniboine River flood by 32%. He recommends restoring 25 to 30% of wetlands in order to decrease severity of future floods.
In conclusion, we thank you for the opportunity to comment on this important plan and hope that the government is prepared to take the bold action required to create a meaningful change in our GHG emissions and nutrient pollutants. The future health of our province and all life that relies on it is at stake.
Respectfully Submitted By,
Vicki Burns and Janine Gibson,
Hog Watch Manitoba
With assistance from Joe Dolecki and Ruth Pryzner