The directors and members of…

The directors and members of the Thunder Bay District Soil and Crop Improvement Association (TBDSCIA) have concerns with the proposed legislative changes to the Nutrient Management Act, 2002 with implications to the categorization to Category 6 of wood ash applications to agricultural land. The TBDSCIA have endorsed the research conducted at the Thunder Bay Agricultural Research Station both under the administration of Ontario Ministry of Agriculture, Food and Rural Affairs and University of Guelph (1992 – 2003) and Thunder Bay Agricultural Research Association since 2003. The wood ash that has been authorized for application as a soil additive to improve soil PH is similar to the wood ash that is the product of brush piles being burnt in land clearing for agriculture or reforestation projects and no documentation is required. The proposed legislation of categorizing wood ash into Category 6 will be cost prohibitive thus even if the farms are willing to do a Nutrient Management Plan the generator will most likely not allocate additional personnel and resources to development and administration that will be required. The wood ash being applied as a soil amendment to improve soil PH in Ontario is very similar to the wood ash being applied in Alberta where the allowable lifetime rate of application is 45 tonnes per hectare in comparison to the allowable lifetime rate of 25 tonnes per hectare in Ontario. Wood ash has and is being used as a soil amendment in Wisconsin, Minnesota, and many other places in North America where pulp and paper industry is active and to our knowledge there are no legislation regulations similar to those being proposed which hampers wood ash delivery or application to agriculture land to this extent. As agriculture producers we must be competitive to all other jurisdictions. It is environmentally beneficial to have wood ash applied to agriculture, forestry and reforestation plantations, as well as it’s ability to improve the PH of the soil. The wood ash also contains potash and micro nutrients which are beneficial to the soil and resulting crop productions. In regards to the concern of heavy metal content, wood ash when applied at prescribed rates is well below the critical limits for these elements. There have been no documented health hazards recorded in regard to the proper application of wood ash to agricultural land in North America and a result the application of wood ash is recommended under the regulations of The Certified Organic Farming Systems. As a means of improving the soil PH wood ash is only a fraction of the cost of limestone which must be imported into the Thunder Bay District. Harmful environmental footprint is greatly reduced when locally available wood ash is applied in comparison to the importing of limestone from Southern Ontario sources which are 1500 km from Thunder Bay. The TBDSCIA appreciates that the Ministries of Health and Environment may have in regards to wood ash applications to agriculture land; however we perceive that these concerns are being adequately arrested under the existing Ministry of Environment Regulation 267/03. It is the opinion of the TBDSCIA that the proposed legislation paragraph 6.1, page 9 will complicate rather than simplify the process. In conclusion, please consider having the regulations in regard to wood ash applications remain under the existing Environmental Protection Act administered by the Ministry of Environment where Certificate of Approval is required.

[Original Comment ID: 104739]