Introduction

Responding to Agriculture and Agri-Food Canada’s proposed Fertilizer Emissions Reduction Strategy has been a major priority for APAS since the consultations were launched earlier this year.

Over the last months, APAS has gathered feedback from producers and recently submitted two documents to the consultation process, including a joint submission with the Saskatchewan Crop Development Commissions and a briefer submission with additional comments we received during consultations with APAS Representatives.

Click here to read the SaskCrops/APAS Joint Submission

Click here to read the APAS Submission

  •  Saskatchewan makes up almost 40% of Canada’s arable land base and producers are world leaders in the development of seeding technology and other farm practices to optimize soil health and productivity.
  •  The 30% reduction target was set without adequate consultation with producers and is based on an incomplete understanding of the technology and nutrient stewardship practices currently used on Saskatchewan farms.
  •  The 30% reduction target in “absolute” emissions presents a significant policy challenge when considering the pace of technological change in the sector and the need to increase food production to meet a growing world population.
  • APAS strongly advocates for an “intensity-based” approach to measuring emissions which would allow for production increases while also ensuring continuous improvements in efficiency and lower carbon footprint
  • Reduction strategies must be based on sound science with verifiable research showing emissions saving and benefits of adoption of new practices. Measuring emissions from farm practices is evolving area of research and Canada cannot afford to get ahead of the science when setting targets for the sector
  • Emissions measurement must be based on modeling that is clear, accurate and accounts for regional variation. The expectation that models will improve calls into question the appropriateness of setting a baseline year to measure reductions
  • Emissions reduction strategies should not interfere with Canada’s contributions to global food security or introduce additional risks to family farm businesses
  • Canada needs to address shortfalls in the design of offset credit for agriculture. For instance, carbon sequestration values from zero-tillage are accounted for in Canada’s emissions inventory reporting, but the practice is excluded as an eligible offset because it is deemed a “common practice”.
  • The federal government has not recognized the competitive constraints emissions reduction strategies and other Canadian climate change policies have on primary producers, especially in relation to the U.S approach to carbon credits and emissions reductions in the sector.
  • Producers are very concerned with the prospect of new regulatory and administrative requirements, including access to program supports, being used to influence on-farm management decisions.

Please contact the APAS Policy Department for any questions
EMAIL: policy@apas.ca
PHONE: 306-789-7774 ext. 4