I am a Certified Crop…

Numéro du REO

013-4388

Identifiant (ID) du commentaire

21876

Commentaire fait au nom

Individual

Statut du commentaire

Commentaire

I am a Certified Crop Adviser and Certified Nutrient Management Planner since the beginning of the Nutrient Management Act began.
I have observed that the 5 year renewals has been an issue for MOE on the enforcement side due to the fact that not all farms have been complying with the regulations.

OMAFRA sends out renewal notices and my company also send out renewal notices to our customers but if they do not respond then there is nothing we as consultants can do to force the customer to submit the renewal submission to OMAFRA. The majority of the time this works fine but there is some that slip through the cracks.

In preparing the 5 year renewals over the years what I have observed is that the first renewal in many cases there is some minor changes to the Strategy from what we had initially prepared. Remembering that we as planners are involved in the very beginning part of the process before construction begins. And the operation of the facility has not started to begin. There is some times changes to facility locations or design from the time we have met the producer and the facility is operating. This can be updated on the first 5 year renewal. Most common in Dairy operations.
Less common in swine or poultry operations.

When doing the second renewal though there is usually no changes and very much a waste of time.

For the very small operations the 5 year renewal is a waste of time.

The way I interpret the proposed changes is that farms over 300 NU that are still required to have an updated Nutrient Management Crop Plan every 5 years will still have to continue to do that to remain compliant under the regulations.

My belief is that this legislation over the years has done a remarkable job in improving the environmental awareness of farmers and improving manure storage handling facilities in this province. The significant improvement in manure management practice and nutrient use efficiency for livestock farmers has improved because of this legislation.

Easying off on the legal renewal burden that OMAFRA and MOECC will have to deal with will save all of us as tax payers some money.