Hog Watch Manitoba, PO Box 61082, Grant Park, Wpg. Mb R3M 3X8

The Manitoba Protein Advantage February 1, 2019 Consultation Comments by Ruth Pryzner Submitted on May 15, 2019
Pigs in pens in industrial barn


Pigs in Confined Space

The consultation document is short on details and long on rhetoric, particularly in relation to the claim that expansion of protein production being environmentally/ecologically viable, in the public interest and economically sustainable for farmers.

The underlying premise of the goal for Manitoba to become the “preferred protein provider in North America” and increase meat protein processimg by 35% by 2025 is desirable and sustainable is unsupportable at many levels if the public interest in a healthy rural economy and a healthy environment are major priorities.

Part of the strategy is to reduce “red-tape.” The Provincial government has started down this road with Bill 34 and Bill 19 to the detriment of long-term environmental sustainability. These Bills erode the capacity for people to meaningfully participate in decisions about how their communities will develop and erodes people’s rights and ability to protect themselves from the agenda of international corporate capital and the industrial food production system. When a government’s priorities centre on supporting big business and the industrial model of producing food, the expected results will not be positive for farmers or the public interest. Bill 19 in particular was designed to reduce and remove the ability for rural people to say no to the expansion of the hog industry and the imposition and placement of large livestock feedlots and confinement facilities in their backyards.

People have a right to the enjoyment and use of their rural property, homes and existing farms, to protect their domestic water supplies from contamination and be free from industrial livestock pollution and negative impacts such as odour, increased traffic, noise, animal diseases that can spread to their non-industrial livestock operations, drug-resistant bacteria and fungi, endocrine disruptors and practices that degrade bird, insect and wildlife populations. Bill 19 further removed control over the planning process from local people in order to meet the desires of industry and large international corporations, not the needs of people.

When I was a municipal councillor, tasked with making development decisions and evaluating conditional use applications for large livestock operations, the fundamental operative principle that guided my decision-making was whether or not a proposed livestock operation would negatively impact the rights and quality of life of folks who had already established a home and farm operation within the area. Numerous pieces of legislation establish such rights. Some legislation such as The Environment Act and Planning Act purport to provide the means to protect people from pollutants and substances that are detrimental to their quality of life and health. When it comes to industrial hog, cattle, sheep and poultry production, these negative impacts are essentially minimized and dismissed by those administering legislation and regulations. For example, the livestock Technical Review Committee interprets legislation and regulation as they determine and almost always recommend that a proposal should be approved. Unmanageable environmental problems are asserted to be mitigable. I have read hundreds of TRC reports and without exception, real potential environmental problems are minimized. Now, what is built into the government’s review structure is the acceptance of proposals that do not have enough spread acres to assimilate phosphorus in manure at annual crop removal rates. Government and the TRC deem a proposed livestock operation to be acceptable if enough spread acres are available at twice the phosphorus crop removal rate.

The Livestock Manure and Mortalities Management Regulation permits the loading of phosphorus onto land up to 823 lbs/acre of Olsen soil test P205. Made in Manitoba Science and reports from world-renowned scientists such as Andrew Sharpley show that the leaky soil bucket is full when approaching the level where phosphorus starts to be regulated in the LMMMR. When more phosphorus is added approaching or exceeding 276 lbs/acre of soil test P, there is an exponential loss of P to the environment. That is what the science says, yet decisions to allow industrial livestock operations are occurring with no regard for this scientific fact. Soil test or labile P is only 10% of the amount of P that is in the soil at the time the soil test is taken. This is standard curriculum from Alberta soil science university experts. This means that the total P in an acre of soil that can accrue as sanctioned by the LMMMR is 8230lbs/acre. Don Flaten et al in their report to the Clean Environment Commission’s review of the hog industry in 2007 reports that the annual average crop removal rate of P in Manitoba is 20.47lbs/acre. This shows that the regulation was designed to facilitate the waste disposal and polluting practices of industrial methods of producing livestock. The Environment Act defines a pollutant as “ any solid, liquid, gas, smoke, waste, odour, heat, sound, vibration, radiation, or a combination of any of them that is foreign to or in excess of the natural constituents of the environment, and
(a) affects the natural, physical, chemical, or biological quality of the environment, or
(b) is or is likely to be injurious to the health or safety of persons, or injurious or damaging to property or to plant or animal life, or
(c) interferes with or is likely to interfere with the comfort, well being, livelihood or enjoyment of life by a person;
The release of excess P into the environment is evident in the Manitoba aquatic landscape. Increasing numbers of watercourses and water bodies are experiencing eutrophication and negatively impacting aquatic ecosystems. Some water bodies such as Lake Wahtopanah (Rivers Reservoir) on the Little Saskatchewan River are compromised due to toxin producing algal blooms occurring each summer which are fed by excess nutrients, especially phosphorus. This is a public health problem for people recreating on the Lake as well as an environmental problem for wildlife that the Lake sustains. Yet, planners and provincial and municipal staff and government continue to ignore the cumulative impacts of developments and food producing practices that fail to and/or ignore the excess application of P problem sanctioned by the province for the sake of expanding the hog and feedlot protein industry primarily controlled and owned by multinational corporations.
The plant protein strategy will be intimately tied into the government-desired expansion of industrial hog production and the establishment of large feedlots for cattle and sheep. By-products from the protein extraction processing of soy and canola is proposed to be fed to hogs and cattle (as well as sheep and poultry). This presents more environmental and social problems for rural Manitobans. The standard best practice used to be a one in four year rotation for canola production. It has been shortened to two years by most producers. With processing plants for canola and soy it is reasonable to conclude that there will be a greater increase in soy and canola production in Manitoba and further denigration of soils and soil bacterial and fungal ecology, an increase in use of insecticides and other life-killing “crop protection agents.
Monocultural crop production and factory meat production have been destroying the web-of-life world-wide. This has been proved by scientists all over the world. The assertion that further expansion of these models of producing food (and integrating them further under a protein strategy where the by-products of plant protein extraction can be used as a source of livestock feed for more factory produced pigs and cattle finishing in large feedlots) is environmentally devastating and is not supported by science and historical reality.

The environmental impacts of monocultural cropping of genetically modified soybean and canola are already evident. These crops use neonicitonoids as a crop protection tool. Neonicitonoids contribute to the decline in pollinator populations, critical for the production of open-pollinating crops. Independent entimologists warn that globally we are in danger of an insect apocalypse. Long term studies in insect populations show that there has been a serious decline in global insect populations over the past 30 years. Insects are the foundation of terrestrial ecosystems and species diversity. The recently released United Nations report on biodiversity warns that a billion species, many of whom are insects, are on the verge of extinction. Continued reliance on pesticides to produce plant proteins contributes to this decline. And what is the goal? To denigrate and pollute the Manitoba environment and water sources to produce protein for export. The costs are too high. What will the world look like for our children and grandchildren when there is a wholesale ecosystem collapse for the sake of corporate profits? People who support this protein strategy obviously don’t care about what current and future generations of people will have to endure.

New drug resistant fungi are starting to kill people. Scientists are finding that there are new public health threats emerging from the fungal world as a result of an increase in applications of fungicides on crops. Experts in bacteria are finding that bacteria species are working together to create antibiotic resistance. No one, no matter how privileged they are to live in nations with modern healthcare will be immune to the loss in availability of antibiotics to cure disease.

I’ve been told all of my life that my job as a farmer is to feed the world. I understood at a young age that this goal is a fallacy and indeed is a most dangerous way of thinking and farming. The marketplace leaves only enough wealth in the hands of producers and workers to keep people producing once they are locked in. The real wealth is captured by transnational corporations. People in nations where there is extreme poverty and food insecurity (affecting almost a billion people), those who need food the greatest, do not have the income to buy our excess production. Furthermore, the poorest people have been increasingly displaced from land and forced to work for a pittance for multinationals or produce cash crops for export to countries that already consume the bulk of the world’s food and other resources. We are not feeding the world. We are feeding those who have sufficient income to buy our protein and grains. This within an evolving and imposed trade regime that enables corporations to sue for compensation for reduced profits as a result of environmental protection policies. So, who is kidding who? What government is truly committed to protecting the critical public interest in a healthy environment, biodiversity, long-term soil productivity, clean water and food producing systems that prevent health problems and negative epigenetic outcomes?

What we are producing and how we are producing it is not enriching biodiversity or even preserving it. This government has laxed the rules on land drainage. No net loss of wetlands has been a policy for decades yet we continue to lose wetlands at alarming rates (if you are a person who cares about such things) and our capacity to store water to recharge groundwater and prevent flooding. More licences are being issued to use ground and surface water for irrigating crops with little regard for negative impacts on ecosystems and sustaining hydrologic systems and wells for future domestic use. For example, the water in the Little Saskatchewan River below the Rivers Dam has been allocated to a corporate entity at 60% of the Reservoirs firm annual yield contrary to sound licencing policy. The operation reports only on water diversion from 4 pumps when the Province knows there are at least 6 pumps diverting water. Last year, in drought conditions where flow was extremely low, water continued to be diverted to irrigate canola and other crops. The priority was meeting the irrigator’s water needs, not protecting the ecosystem of the Little Saskatchewan River and the public interest in it.

The fact is that Manitoba’s regulatory system is insufficient to result in sustainable agricultural outcomes. Manitoba food production has been hi-jacked by corporations interested in maximizing profits at the expense of our ecology – the plant, insect and animal diversity upon which our lives depend. Corporations cite contributions to the province’s GDP, growth and jobs. Yet there are less farmers, people whose work and presence in rural areas are essential for healthy rural communities. The Province encourages immigration to supply workers for its industrial corporate systems, creating a class system where those who come from countries where they live in abject poverty and face serious human rights violations on a daily basis see themselves as lucky to be here working under conditions most multi-generational settler Canadians won’t tolerate.

With the loss of the Canadian Wheat Board and assaults on the supply-management system for the dairy and poultry sectors, real farmers who produce protein in step with nurturing ecological system health have found themselves more at the mercy of transnational grain companies and meat companies. In 1974 there were over 14,000 farmers producing pigs. Now there are a mere 203 pig producers registered with the Manitoba Pork Council, two of which are Maple leaf and Hy-life corporations. Most of these producers only produce for these two corporations under contract, with Maple Leaf owning the pigs, renting pig places and producers being technicians.

The province is facilitating more hog finishing barn capacity for these two corporations while hog finisher producers are losing money finishing hogs in an industrial method that is harming the environment. It is clear that the best interests of these corporations is what the Minister of Agriculture is concerned about, not farmers. The minister also thinks that cattle production should increase to pre-BSE levels. Already beef producers are at the mercy of multinational beef packers. See the National Farmers Union report on the beef sector authored by Darrin Qualman wherein the evidence is clear that the main benefactors of all the risk-taking and hard work by cow-calf farmers are vertically integrated transnationals. The accuracy and quality of Qualman’s report is unchallengable.

My ancestors left Europe to escape the negative consequences of industrialization on peasants/farmers. Gains made in Canada to hedge against the new feudal system have been destroyed by corporations supported by government policy and law. Politicians of all political stripes say they care about farmers and the environment. Yet, the model of food production and the function of the economy and regulatory systems does not serve the needs of people. It has been transformed into a system that services global capital and corporations.

Rural people’s standard of living, our health and the resiliency of nature will further decline if this protein strategy is allowed to proceed. Government should marshall its resources and extension services to facilitate food production methods and systems that significantly reduces and eventually eliminates reliance on “crop protection technologies” that have destroyed the “pest” balance that nature had provided and teaches us once again how to produce food in harmony with nature and respects the needs of livestock as sensient beings rather than treating them as merely meat/protein commodities on legs.

To be clear, I have deliberately chosen not to provide a list of scientific studies, reports and references. I have made this choice because, it has been my experience in doing so that information that does not fit into or contradicts the corporation supporting beliefs of decision-makers is regularly dismissed, ignored and rejected. The natural systems upon which all life is supported are reaching a tipping point. It is evident that the authors of this protein strategy hold beliefs that are at variance with reality and require a fundamental shift to become aligned with reality.

I lost family during World War 2 who believed that they were protecting the world from anti-democratic and fascist control. What would they say now if they knew that fascism is alive and well in Canada, that the take over of governments by corporate interests has happened, is thriving and the democratic tools for people to protect their individual and collective interests have been further eroded by the party in Manitoba that says they are for advancing small business and protecting the little guy?

What will people living 20 to 30 years from now say about the decision to further industrialize animal and crop production with its commensurate and expected environmental and rural quality of life degradation? Indigenous people on Turtle Island teach that to be regarded as having lived a good life, future generations can regard us with honour for having made decisions to live in concert with nature and in ways that ensure that the web-of-life is protected.

Finally, there is no evidence that there has been any consultation with First Nations, Metis or Indigenous people about the potential negative impacts that this protein development strategy may have on their lands and rights.

At a minimum, for the above reasons, I urge the provincial Government to abandon this strategy and re-think its unbridled support for international corporate interests and turn its attention to supporting ecologically sound agriculture, real farmers and to protecting the public interest in the environment, clean water and land and healthy rural lifestyles while engaging in true reconciliation with indigenous peoples.