July 22, 2021 Naomi Horst…

July 22, 2021

Naomi Horst
Food Safety and Environmental Policy Branch
1 Stone Road West
Ontario Government Building, 2nd floor, Southwest
Guelph, ON N1G 4Y2

Via email and ERO Submission - naomi.horst@ontario.ca

Legislative and Planning Services
Planning Services
Halton Region
1151 Bronte Road
Oakville ON L6M 3L1

Subject: ERO 019-3849 Nutrient Management Act Further Burden Reduction Opportunities

Dear Ms. Horst:

Thank you for the opportunity to comment on the proposed changes to the Nutrient Management Act (ERO 019-3849) to remove the regulatory requirements for five-year expiry of the Agricultural Operation Planning (AOP) certificate and to streamline nutrient management protocols under the Nutrient Management Act, 2002. Halton Region staff have reviewed the documentation, and canvassed several Halton-based associations such as the Ontario Federation of Agriculture, the Halton Region Federation of Agriculture, Halton Soil and Crop Association, Peel/Halton Beef Producers and our Halton Agricultural Advisory Committee to provide the following response.

Halton Region’s agriculture sector plays a critical role in the development of Halton’s economic, environmental and social prosperity. Horse and equine, oilseed and grain, greenhouses and nurseries, hay, cattle, and fruit and vegetable production make up the majority of agricultural operations in the Region. We recognize the need for proper management of a variety of nutrients from agricultural operations for the protection of the natural environment, which in turn provides a sustainable future for agricultural operations and rural development.

The Nutrient Management Act (NMA) is an important tool to empower farmers to prepare a farm-based Nutrient Management Strategy (NMS) and/or Nutrient Management Plan (NMP). The Agricultural Operation Planning (AOP) certificate ensures that a qualified person is preparing an NMS/NMP. We support the Province’s direction to amend the NMA regulation to remove the automatic five-year expiration associated with an AOP certificate so that the certificate will never expire. We believe this will provide cost and time benefits for farmers that in turn will help strengthen the agricultural industry. Furthermore, we believe updates to the Nutrient Management protocol to reflect the changes in regulations is important to provide clarity and to streamline nutrient management protocols. However, as the Province’s proposal does not contain a draft protocol, we cannot provide specific comments regarding this component of the proposal.

As the proposal lacks detail about the Nutrient Management protocol changes we note that certificate holders and certificate applicants should be consulted to fully understand any changes to the technical and scientific standards in the protocol before it is amended by the Province. In addition, continued training opportunities for certificate holders and certificate applicants should be provided by the Province when changes are made to the protocol.

Furthermore, we support the direction of a simplified renewal process for NMPs where no substantial change to the operation has been made. A simplified process for these circumstances will continue to save farmers and government time and money without compromising environmental protections.

We appreciate the opportunity to submit these comments as we collectively work to develop mutually agreeable regulations and protocols that will ensure the long term viability of the agricultural industry while protecting crucial environmental resources.

Sincerely,

Curt Benson, MCIP, RPP
Director of Planning Services and Chief Planning Official