The Oxford Coalition for…

The Oxford Coalition for Social Justice is heartened by the process which will develop an Agricultural Impact Assessment Guidance Document and submits these comments in good faith in hopes of improving the particular interests of residents of Oxford County, the specific concerns of agricultural communities across the province as well as the needs of Ontario. These comments are organized around the following themes:
• Prime farmland and Food
• Agriculture and Industrial Products
• Prime Farmland and “Interim” Industrial Uses
• Prime Farmland and Permanent Development
• The Water, the Water, the Water
• Qualified Persons and the Management of Soils and Water
• The Impact of participation in rigorous Agricultural Assessments on Rural Communities
• Self-Determination.
All quotations in the following not ascribed to other sources are from the draft Agricultural Impact Assessment Guidance Document.
Food is vital to Ontario for nutrition for residents, as a significant part of the economy both internally and when shipped beyond provincial and national boundaries and as an essential element to community. Prime farmland in Ontario is located also in the most southerly part of Canada, meaning that for many farms, crops are possible which cannot grow in the limited season of the prairies, for instance. Prime farmland is therefore a resource not to be wasted. “They aren’t making any more of it” goes the popular saying in farm country. In fact, for a variety of reasons and causes, prime farmland and even specialty croplands are diminishing. They are irreplaceable. Loss of prime farmland results in the loss of food, money and communities. “Farmland in Ontario is a finite and valuable resource”. The Oxford Coalition for Social Justice advocates for weighing the present and future value of farmland to sustaining the province very highly in any decisions.
Prime farmland not only produces food, it produces industrial products in several ways. Corn crops produce industrial sweeteners and ethanol which runs vehicles. Bio-digesters can feed compressed natural gas systems to run a variety of agricultural, industrial and personal equipment. Agricultural by-products, fibre, skin and bone have value. An entrepreneur in the Guelph area uses agricultural fibre to produce automotive parts, linking those two important industries in southwestern Ontario, and by coincidence, being associated with high-value vehicles whose economic and aspirational value surpasses the impact of Matthew McConaughy. Animal hides become leather for industrial and clothing uses. Bone meal is returned to croplands or sold in nurseries as an essential element to helping urban trees survive a less hospitable environment. The Oxford Coalition for Social Justice, then, suggests that in any agricultural impact assessment a full cost accounting include all secondary revenues and benefits from retaining prime farmland for agricultural uses.
Prime farmland is often designated for “interim” industrial uses due to its location in proximity to urban development which creates a demand for aggregate used in construction. Given the perverse effects of the aggregate industry’s oft-repeated phrase “close to market” aggregate seldom is removed or created or reprocessed within urban boundaries, but typically in adjoining productive land areas. Communities are told that aggregate extraction for sand, gravel, stone or clay will be for an interim period, but in most cases, pits and quarries outlast their neighbours’ life-spans. Aggregate extraction, to use the language of the industry but in its proper context, “sterilizes” food land and “extinguishes” any hope of food sustainability. Further, rehabilitation plans for pits and quarries, which may include references to restoration to agricultural uses, do not account for the reduction in available land to work as a result of the steep slopes created by extraction. Nor do those rehabilitation plans recognize the scientific evident of the loss of soil fertility when it is scraped, piled in berms, and planted in acid-producing tree covers. What to do with the vast number of ponds which relate to surface water or ground water flowing in is not clear in terms of rehabilitation plans. When rehabilitation plans suggest recreational lands contiguous to farmland, they could produce a use that does not conflict with agriculture and food production in neighbouring farms, but nonetheless mean an absolute and permanent reduction of available farmland, most often prime croplands. Sadly, rehabilitation seldom occurs. The Oxford Coalition for Social Justice therefore recommends that any Agriculture Impact Assessment assume that the least viable rehabilitation or utter neglect be considered the result of the so-called interim use of agricultural land for aggregate. Rehabilitation should not be considered as part of an assessment since over the interim, a period not described in any legislation or regulation, there is a loss of farmland that could extend over centuries and will likely become permanent. Further, reprocessing of aggregate, which means stockpiling asphalt, ceramics, tires, cement, concrete and all their designed or accidental contaminants, should not be occurring in pits and quarries where they expand and extend the threat to prime farmlands and the communities within them. The release of contaminants and/or dust and/or fine particulate matter during the reprocessing into the air, onto adjoining crops and into water represents serious hazards to human and animal health as well as to the economy of Ontario. Because stocking of aggregate for reprocessing in pits and quarries extends the life of the operation, it extends the period of the interim toward infinity.
Prime farmland is often taken out of food production by the extension of manufacturing and warehousing beyond urban boundaries. In fact, in southern Ontario, bypasses constructed to get traffic out of urban cores also results in urbanization of rural areas along them, both residential and industrial uses. Pavement of roads, parking lots and loading docks, like aggregate extraction, “sterilizes” food land. Laying foundations and cement factory or warehouse floors “extinguishes” it. Dumps are an aberrant form of industrial development that marks the failure of industry to recover resources, to plan for recycling, and to save costs by reduction of waste. Any assessment of an application for aggregate extraction needs to consider that dumps are permanent, frequently illegal, and often dangerous to human and environmental health. They need to be treated as a hazard to agricultural industry and communities. Conversely, food processing makes sense closest to food production, so is a separate category of consideration, and since nutrition diminishes with time and distance it travels before transformation, packaging, sorting and processing, needs to happen in rural Ontario. Nonetheless, the establishment of such food processing facilities needs to consider the impact on food production. Since “an AIA is a tool to identify and evaluate the impacts of non-agricultural uses to avoid, and where avoidance is not possible, minimize and mitigate impacts on agriculture” it is advisable that only non-agricultural uses required to directly support agriculture be considered. The Oxford Coalition for Social Justice recommends that Agricultural Impact Assessments of land used for agri-tourism, processing facilities and food warehousing advantage these especially where they convert less productive lands, class V and below, to these complementary uses as a form of mitigation of impacts.
Aggregate extraction uses water and competes with agriculture for it. Permits to take water, issued through the Ministry of the Environment, Conservation and Parks, are too often without adequate science to define the available quantity and quality of water. Further, by interrupting surface water flows and/or digging into aquifers, even multiples on one site, aggregate extraction interferes dramatically with available water in the directly adjoining area and downstream. Water for farms is used by those residing on them, human and animal. Indeed, water for livestock requires purity and quantity. Similarly, irrigation of crops requires water which can be assured to be uncontaminated so that it neither harms the crop themselves or the eventual consumers. Since farms rely for the most part on private wells, any consideration of water supplies needs to include farm wells as well as municipal ones. Residents in rural communities have a right to have their private wells included in the agricultural impact assessment. They may work on the farms. They may be retired from farms. They may be the locals in supporting industries. Since all share the same aquifers, all should share in the benefit of a full and careful analysis of the water. The Oxford Coalition for Social Justice recommends that water be a prime consideration in all Aggregate Impact Assessments and include, as recommended by the OFA, all private residential and farm wells as well as community and municipal systems. Surface water should not be excluded from this either.
Aggregate extraction produces waste water with stunning lists of chemicals in solution, in addition to the rock dust in suspension in it. That the chemicals, in one case in Oxford, though not likely an anomaly, contained chemicals associated with stone, pesticides including some banned from Ontario, and e-coli bacteria in high concentrations is supported by documents produced by quarry owners. This is more concerning where aggregate is mixed on site, either virgin aggregate from other pits or quarries, or reprocessed aggregate. According to Bill 56, however, recycled aggregate will be sourced from “construction work which means constructing, altering, decorating, repairing or demolishing buildings, structures, roads, sewers, water or gas mains, pipe lines, tunnels, bridges, canals or other works”. Demolition is one of the areas of immense concern since demolition waste contains “high concentrations of heavy metals” says emeritus Professor Ric Holt of the University of Waterloo, including “arsenic, boron, cadmium, chromium, nickel, cobalt, lead, manganese, mercury, molybdenum, selenium, thallium and vanadium”. Thalium, used in the manufacture of glass, affects the nervous system, lungs, heart and liver. “It has caused death”, says Medicine Net. Vanadium, a trace element in our diet, is known to interfere with white blood cells, needed to fight infection according to the University of Maryland which warns of toxicity above 1.8 mg. The presence of any of these chemicals in air, land or water in any levels which health officials might have difficulty with is troublesome. Their impact on agriculture can be measured in the litres of water consumed daily by residents of farms and farm communities, by livestock, in food processing and in irrigation. Thus, the Oxford Coalition for Social Justice recommends that Agricultural Impact Assessments should preclude any pits or quarries where reprocessing of any kind might occur in proximity to farmlands.
Agricultural Impact Assessments similarly need to consider the value to communities of the filtering capacity of soils, sand and gravel over aquifers. The removal of glacial features such as eskers, moraines, drumlins or kames negates the beneficial effects of these landforms and contributes to the movement of contaminants into water. Emerging science also indicates that certain chemicals adhere to aggregate particles. As filtration, then these are highly valuable to downstream users of ground or surface water. In addition to extraction providing vectors for contamination, gravel washing and crushing can result in the release of significant quantities or mixes of chemicals into water, resulting in health hazards for humans and livestock. Livestock and food crops irrigated with contaminated water where chemicals have entered because of loss of filtration represent both indirect and direct threats to human health. The indirect threat is perhaps even larger than the direct threat due to bio-accumulation in animal organ tissue consumed by human or in milk from cattle. The Oxford Coalition for Social Justice therefore recommends that Agricultural Impact Assessments consider filtration as a valued asset along with water and prime farmland.
The Oxford Coalition for Social Justice recognizes that agriculture is not simple. It involves great dollops of science, business and communication skills, and engagement in constant learning within the geographical and professional (farming) community. Qualified persons involved in Agricultural Impact Assessments need to have broad understandings of these and specific knowledge. The description in the draft document contains many valuable statements related to Qualified Persons. “Qualified Professionals’ qualifications should include knowledge in: Agri-businesses, agricultural supply chain linkages, rural/agricultural economic development in Ontario, and within the GGH, the agri-food network” as stated. Further, “where relevant” is insufficient; it is always relevant that Qualified Persons have expertise in “Rural and agricultural land use planning, Canada Land Inventory (CLI) classifications of capability for agriculture assessment” as well as “a practical understanding of soil science, including the ability to review technical information from non-agricultural disciplines and assess its relevance and utility in identifying potential agricultural impacts”. Qualified Persons need to have “demonstrable experience evaluating and assessing agricultural impacts and university or college degree(s) in one or more of the following: agriculture, soil science, geoscience, [ … ], resource management-related disciplines, environmental-related disciplines, agricultural engineering, or land use planning” and chemistry for reasons made clear related to wastewater, solid waste, etc. Landscape architecture, in the ellipsis in the previous sentence, may be of lesser importance while, in an era when zoonosis is a worry for bio-security, a clear understanding of theory and practice of bio-security is necessary to support the viability of Ontario farms . “A code of ethics and ongoing professional development” are clearly a minimum requirement, and one which needs to be coupled with “demonstrated experience providing objective, professional judgment, advice, and testimony as an expert witness”. Communities need to be convinced of the impartiality of such Qualified Persons and the Oxford Coalition for Social Justice is aware that the breadth of required knowledge and experience may necessitate that Qualified Persons be plural. Teams offer added assurance.
Qualified Persons are also evoked in recent work on Excess Soils by the Ministry of the Environment, Conservation and Parks. That parallel is matched by the similarities among waste aggregate ready for reprocessing, trash destined for dumps and excess soil. In all cases, they are by-products of an effluent society and of policies encouraging urban intensification. Excess soils represent a variety of threats to agriculture in Ontario through the chemical contaminants they contain, the migration of non-native and aggressive species, the alteration of surface flows, the burial of topsoil by less fertile subsoils or dead soil, the attendance hazards of haulage. The outflow of water from lands whose grade has been altered by excess soil means that Agricultural Impact Assessments need to be mandatory for any proposal to move soils into, onto or adjacent to farmlands.
Rigorous Agricultural Impact Assessments are clearly a necessity. For agricultural communities they offer reassurance for continued sustainability for them and the province. On the other hand, participation in these studies will require time and energy as well as expertise by farmers and rural community members. To sustain the involvement of volunteers, there need to be intervenor funds made available to local community organisations to employ staff and/or experts to interpret the vast and complicated information. The small populations of rural communities do not necessarily include people with the heady mix of abilities and credentials described for Qualified Persons, yet to participate in a meaningful way, community members need to have access to supplementary revenue, personnel and/or recognized researchers and experts. The Oxford Coalition for Social Justice recommends that the Agricultural Impact Assessment Guide Document describe the added burden to agricultural communities required by these assessments and the need for them. Further, we recommend that the Ministry of Agriculture, Food and Rural Affairs designate teams of staff across the province to support communities coming to grips with major projects whose potential impact is borne they them.
Rural communities have spoken clearly about the right to decide on landfills, high speed rail, excess soil, highway expansion, nuclear dumps, etc. A future which members of the Oxford Coalition and its members, associates and allies approve is clearly one that prioritizes food production over environmental destruction. Over 70 communities across Ontario have signed on in solidarity to www.demandtheright.ca via official motions of their municipal councils. Local self-determination needs to be considered in the development of processes meant to assure human health and economic prosperity go hand and hand. The sacrifice of the former for the latter is not ethical since the purpose of economic activity is the benefit of the population, and since, the population bears the costs for thoughtless impacts. Mixed waste dumps, excess soil dumping, dangerous and hazardous projects are among these. Like rural community groups, municipalities need to be given the resources to fully examine agricagricultural impacts, to discuss the scientific and social implications. Roles and responsibilities, Durham points out, are not as clear as they might be. Municipal and community responsibility means that there must be adequate resources provided by project proponents whose plans may have impact on agriculture and agricultural communities. The Oxford Coalition for Social Justice advocates for increased capacity for rural community groups and their formal structures such as municipal councils through intervenor funds.
The Oxford Coalition for Social Justice appreciates the work done by the Ministry of Agricultural Food and Rural Affairs on a document to provide guidance around the assessment of impacts – beneficial or negative – on communities. These comments are offered in good faith to support that work and a sustainable future. We live in Ontario’s food belt, and hope that its productivity will be expanded, and the duration of its soils fertility extended.