Comment
As a NMS consultant I find this proposal confusing. If we aren't returning to the sites every 5 years to check for changes, what is to keep a farmer from switching his barn from beef to hogs for example? If they do this switch within the existing footprint there would not be anything that triggers an awareness of what they are up to. ( No need for a building permit) Yet the farmstead nutrient load and nutrient storage has changed significantly.
I have caught some very significant changes at the 5 year renewal mark. Sometimes to the point of a complete renewal to submit. Those changes would go undetected with this proposed change. Why is that good?
How many new catch basins and tiles close to manure storage have been caught in audits? That weren't there when a NMS was done by the consultant. Many things that shouldn't be done, will go unnoticed.
Who better to check on the farmstead than the consultant that originally did the Strategy?
Submitted January 8, 2019 4:46 PM
Comment on
Proposed regulatory amendments to Ontario Regulation 267/03 under the Nutrient Management Act
ERO number
013-4388
Comment ID
17153
Commenting on behalf of
Comment status