Additional changes to the Fertilizers Act and Regulations
Implementing cross compliance for fertilizer distribution licences
Insurance to cover losses associated with fertilizer use reductions
Carbon taxes and other GHG mitigation measures
Reducing corporate concentration in the input sector
Additional changes to the Fertilizers Act and Regulations
Priority product development for soil health, financial and logistical assistance to SMEs to help with safety testing
Based on the example of the AAFC Minor Use Pesticide program, regulators and program staff should work with manufacturers and importers on priority materials to advance soil health objectives, and particularly for SMEs, provide assistance on trial data and applications for approval. The structure could be modelled on the Minor Use program which has an annual multistakeholder priority setting meeting. Different government units assist with data collection, analysis and application submissions. There's also data sharing with the US. All this could help reduce resources to devoted to low need (but often commercially appealling) products.
Return to efficacy testing and post-market impact surveillance
Returning to efficacy testing regarding soil health objectives is warranted. The testing protocols should integrate a number of evaluative steps that examine whether a fertilizer does or doesn't contribute to improving soil health parameters and under what conditions. Devising and validating the protocols is a significant undertaking, but implementing this at the Substitution stage provides time for the research to be completed. Associated with this, companies should be required to implement post-market surveillance programs that confirm (or disconfirm) what has been submitted for efficacy trials to regulators. Regulators would, then, also need to devise surveillance protocols for companies to follow.
Reducing permitted application rates, based on assumption that farmers are diversifying crop rotations and doing other ecological soil management practices
Currently, applicants are not required to provide evidence of appropriate fertilizer use on the basis of optimal crop rotations. Instead, most directions for use (which are mandatory on labels under the Regulations) are based on individual crops, as if produced year over year in a monoculture. However, nutrient use and mobilization is very affected by crop sequencing.
For example, a classic soil conserving Prairie rotation is oilseed (e.g., canola) - cereal (barley) - pulse (peas) - cereal (wheat). The rotation can also be extended and made more complex by working in winter cereals and alfalfa in certain regions. Applicants should be required to submit reference rotation fertilizer recommendations for the cycle, taking account of organic matter additions and contributions from the pulse crop. This requires changes to testing protocol guidance. Conditions on approvals and re-evaluations related to rates would then need to reflect this new information and analysis.
Implementing cross compliance for fertilizer distribution licences
At the substitution stage, cross-compliance is being implemented across numerous areas of change (see for example, Goal 5, Sustainable Food, Substitution). Under section 5.2 of the Act, the Minister can grant licenses to distributors when conditions are met. As a condition, changes to regulations should tie approvals for distribution licences into sustainable protocol adoption, in other words, distributors must provide proof that their fertilizer use advice is consistent with the protocols referenced by the Act and Regulations. If applicants can not provide such evidence, distribution licences would be denied.
Products that are manufactured, but not approved, in Canada for reasons related to lack of need or lack of compatibility with sustainability requirements should also not be permitted for export. This is to comply with Goal 10.
Insurance to cover losses associated with fertilizer use reductions
The National Farmers Union has posited the creation of insurance instruments that cover farmers in the event of losses associated with management changes that reduce fertilizer use (NFU and Qualmann, 2021). Some private insurers have introduced various versions of this concept in the US over several decades, but the Canadian version would be public, following on lessons from BRM programming funded by the federal and provincial government with farmers. The insurance would be triggered by significant net income losses linked to management change.
Carbon taxes and other GHG mitigation measures
See Goal 5, Sustainable food production. The federal government proposes to impose emission caps of 30% on the fertilizer sector consist with commitments under the Strengthened Climate Plan. But it appears that it will leave it to the industry and agricultural sector to figure out how, a relief to the fertilizer industry which feared that fertilizer consumption reductions would be imposed (Briere, 2022). To hasten adoption of and harmonization with sustainable production protocols, the federal government should also imposed mandatory consumption reductions.
Note that research using wind power and other "green" processes to fuel the Haber-Bosch process rather than natural gas are underway, but it will take some time before their effectiveness and viability are demonstrated (Arnason, 2022). This would certainly reduce the carbon footprint of nitrogen fertilizer but does not on its own address the soil health problems.
Reducing corporate concentration in the input sector
See Goal 3, Reducing corporate concentration
