Modifications to the Fertilizers Act, Regulations and Guidances
Modifications to provincial Fertilizer and Nutrient Management legislation
Sustainable protocol adoption
Improving ecological nutrient management research
Changes to provincial extension services
Modifications to the Fertilizers Act, Regulations and Guidances
A preamble about soil health and ecological soil management is needed.
The Act does not have a preamble that situates fertilizer regulation and use within a soil health perspective. One is needed first for the guidances, and then later it can be added to the Act (at the Substitution stage). The preamble should provide:
- an acknowledgement that soil is at risk
- an agroecological interpretation of soil health
- a recognition that fertilizer approvals and use must contribute to soil health, while supporting productivity, safety and environmental protection
- a statement that soil health criteria will be used as part of the review of fertilizer applications
Changes to label statements for biological materials regarding role of organic matter in soil health.
The value of organic matter is poorly represented on labels. For biological fertilizers and supplements on the Primary Materials list with significant levels of organic matter, the Guidances should name the need for a label statement that describes the role of organic matter in soil health.
Change definitions
The distinction between fertilizers and supplements is not representative of the full role of different materials in soil fertility. Instead, there should be two categories:
- Nutrients and organic matter
- Secondary materials that stimulate or support nutrient provision
Changes to grade requirements
Organic materials with NPK levels under 5 should not required to report a specific grade. Instead, a general statement to the effect that the material is less than 5-5-5 should suffice. The current system makes organic matter look inadequate compared to synthetic fertilizers, but with this change and a label statement about the value of organic material, there will be more recognition of organic material value.
Modifications to provincial Fertilizer and Nutrient Management legislation
As discussed under Current Government Initiatives, nutrient management policy, legislation and programming at the provincial level is highly variable in effectiveness. This can not be attributed to unique provincial conditions, since soil quality is an issue in most significant production regions of the country. Although soils have differences in different regions, and the symptoms of the problem may differ, they have similar roots and require similar solutions in the broad strokes. It is only when decision makers take an unecological view of soil health problems that provincial uniqueness can be argued. All provinces should be taking an approach comparable to Quebec which has the most ecological soil health program in the country.
Sustainable protocol adoption
Sustainable production protocols, based on systems that support soil health, are discussed under Goal 5, Sustainable food production. To bring tangible application to the new preamble, these protocols can be incorporated by reference under 5.1(1) of the Act. By doing so, the Act would signal the kinds of farm practices consistent with a soil health approach. Any standard referenced in the Act should meet the minimum requirement of Integrated Crop Management (sometimes referred to as Integrated Farming). In practical terms, this approach uses a combination of cultural practices, biological and synthetic fertilizers to enhance soil health and crop nutrition. This approach has been used in Europe for over 25 years and is the basis of some of the EU's supports for sustainable farming. More specifically, any referenced standard should at least be equivalent to the Soil and Crop Management provisions of the European Initiative for Sustainable Development in Agriculture's Integrated Farming Framework.
Improving ecological nutrient management research
Priorities for sustainable agriculture research, including soil health, are outlined under Goal 3, Public research and information dissemination, Efficiency. See also Lynch (2022).
Changes to provincial extension services
Post WWII, extension services shifted to fertilizer promotion, and increasingly away from complex crop rotation design and biological sources of fertility. Now they must promote organic matter, crop rotation, cover and intercropping and composting, with fertilizer recommendations a subsidiary part of the extension process. Unfortunately, at the moment, most provincial agriculture departments don't have enough expertise to do this. Since the 1990s, direct agricultural extension in Canada has been declining, a strategy to increasingly leave one-on-one advising to the private sector, and have government officials involved in wider angle facilitation of farm-related processes, with a particular focus on line information delivery. In late 2020, Alberta announced it was eliminating most of its remaining research and extension personnel (Ferguson, 2020). However, reducing direct contact with farmers is a recipe for reduced ability to help shape what farmers do (Milburn et al., 2010). Leaving things like soil fertility in the hands of advisors working for fertilizer firms and retailers has resulted in the bundling of advice with product sales and has reinforced the overemphasis on synthetic sources of nutrients. Private firms have little incentive to encourage farmers to use the internal resources of the farm for fertility. Since public extension has always been about wider public purposes (though arguably in hindsight much of it misdirected), it is clear that a public problem like improving soil health needs public, not just private, extension resources.
However, a new extension model is also needed, working with farmers on sustainable transition planning, much different from traditional approaches (see Goal 5, Sustainable Food, Substitution, Transition Advisory Services). There is some history of this approach, particularly in Quebec with the clubs agro-environnementals. The model can be used to deliver a range of sustainable farming initiatives, and take a range of forms. Options include:
- Fully operated by provincial agricultural extension staff - the challenge here is that budget and staff cuts have significantly reduced provincial capacity in many regions of the country, so it would mean new budgetary investments in re-invigorating staffing, with associated sustainable transition training requirements for extension personnel.
- Advisory service framing and operational templates set by the province, but contracted to a third party with the on-the-ground expertise for delivery, with the provinces picking up the tab. This is done commonly with other environmental programming.
- The Environmental Farm Plan program of the Canadian Agricultural Partnerships has some foundational elements that could transition into suitable advisory services, in particular the cost-shared funding programs for advisors. This would require that the next iteration of the Canadian Agricultural Partnerships have new negotiated dimensions between the federal and provincial governments to establish tripartite funded advisory services. Assuming the CAP continues with new agreements every 5 years, this is the most viable approach because it creates a national initiative, with some room for provincial variability, and has a more diverse funding base, including farmers. It also helps address some of the limitations of the current EFP, especially if a mandatory requirement for farms on which soil health problems are identified in the self-assessment phase of the EFP. Third party delivery is also possible in this option, since some provinces currently operate their EFP programs in this way.
Because soil health is such an encompassing concept and practice, it makes sense for a soil health advisory service to be part of a whole farm approach to improving sustainability. An advisory service requires an integrated team which can sometimes create problems for traditional organizational models designed around specialties. It also means extensive rewriting of extension documents and websites
