A copy of our comments has…

A copy of our comments has been send, in pdf form, to soilhealth@ontario.ca

CropLife Canada appreciates the opportunity to provide input into Ontario’s Draft Agricultural Soil Health and Conservation Strategy on behalf of Canada’s plant science industry. CropLife Canada is the trade association representing the manufacturers, developers, and distributors of plant science innovations including pest control products and plant biotechnology for use in agriculture, urban, and public health settings. We are committed to protecting human health and the environment and we believe in driving innovation through continuous research.

CropLife Canada recognizes the importance of healthy agricultural soil for the long term sustainability of the agricultural sector and we applaud the Ontario Ministry of Agriculture, Food and Rural Affairs for taking action on soil health. The plant science innovations developed by the member companies of CropLife Canada have played, and continue to play, a critical role in improving sustainable agricultural practices that promote healthy soil by improving soil biodiversity and conserving soil nutrients and moisture.

Health Canada’s Pest Management Regulatory Agency (PMRA) and the Canadian Food Inspection Agency (CFIA) are responsible for reviewing many of the aforementioned plant science innovations before they can be registered for sale or use in Canada to ensure they are safe for human health and the environment. CropLife Canada cautions that additional prescriptive regulatory burdens not based on rigorous scientific evaluation and assessment will have the net effect of stifling investment and innovation in Canadian agriculture. CropLife Canada also strongly supports an environment of continuous innovation and a timely, science-based regulatory system to help ensure the rapid adoption of new technologies that will preserve soil health and biological diversity.

In closing, we would like to reiterate our thanks for the opportunity to provide input into this initiative. CropLife Canada and its member companies would be pleased to contribute to this ongoing dialogue and look forward to working with the Government of Ontario to realize its vision for healthy and productive soils now and for generations to come. Sincerely, Maria Trainer, Ph.D. Managing Director, Science and Regulatory Affairs, Chemistry

Danielle Soulard Science and Regulatory Affairs Officer

Darell Pack Director, Provincial Regulatory Affairs and stakeholder Relations

Introduction CropLife Canada agrees that healthy agricultural soils are the foundation of a strong, sustainable agri-food system. Indeed, we are long-standing supporters of the Soil Conservation Council of Canada (SCCC), which was founded in 1987 to advocate for soil conservation on a national scale. As the world’s population continues to grow, Canadian agriculture will play a critical role in meeting the demand for increased food production; however, we will need to do this in a sustainable manner that protects our environment and promotes biodiversity. As such, it is important that the demand for increased food production be met using existing cropland while avoiding the depletion of resources such as water, fuel and soil.

At the global, national, and regional levels, there are considerable existing data on soil management best practices, but, in general, there is limited site-specific research and information readily available for those who need it. For example, Agriculture and Agri-Food Canada’s (AAFC) Agri-Environmental Indicators series track whether the agriculture sector is moving towards or away from environmental sustainability on a Canadian scale. Generally, trends in soil health across Canada from 1981 to 2011 show consistent improvement (as measured by soil erosion, soil organic matter, and soil salinization indicators), attributed to improvements in land management practices such as conservation tillage [1]. Despite these improvements, however, the same indicators reveal that Ontario’s soils are undergoing a significant loss of organic carbon and more than half of the provinces soils are at a moderate-to-high risk of erosion [1]. Specific threats to Ontario’s soils include pressure from increasing demand on soil for food production; farming practices that may degrade soil health, extreme weather events; and the balancing of economic priorities with environmental conservation [1].

CropLife Canada recognizes the importance of healthy agricultural soil for the long term sustainability of the agricultural sector and we applaud the Ontario Ministry of Agriculture, Food and Rural Affairs for taking action on soil health. In light of the limited Ontario-specific soil research and the concerning results from AAFC’s indicators, CropLife Canada strongly supports OMAFRA’s proposed action to explore adapting a specific set of soil indicators at a more detailed scale. There is a need to assess the state of agricultural soil health over Ontario’s varying landscapes, and to track any changes over time. CropLife Canada agrees that establishing baselines in research is essential, so that improvements can be monitored and emerging trends can be followed.

Plant science innovations have played a critical role in improving sustainable agricultural practices that promote healthy soil by way of enabling no-till and conservation tillage practices and thus reducing soil erosion and reduced greenhouse gas (GHG) emissions, reducing overall land-use through yield enhancing technologies, as well as improving soil biodiversity and conserving soil nutrients and moisture. We are proud of the role that our industry’s innovations have played in facilitating the adoption of these practices. Our industry is at the leading edge of agricultural innovation and we believe we will play a critical role in realizing the Government of Ontario’s vision as outlined in the Draft Agricultural Soil Health and Conservation Strategy (the Strategy).

Increasing demand for food production The Food and Agriculture Organisation of the United Nations (FAO) predicts that global food production must rise by 70% to meet food needs by 2050 [summarized in 2]. This demand must be met without an appreciable increase in land under production, which will require innovative solutions to preserve soil health while improving agricultural productivity. CropLife Canada believes that access to, and application of, existing and future plant science technologies and innovations will be critical to a broader national, and global, food security strategy.

Without plant science innovations, it is estimated that Canada’s agriculture area would need to increase by 50%, or an additional 14.2 million hectares to produce the same level of crop production output that is produced today – a land mass greater than the combined area of New Brunswick, Nova Scotia and Prince Edward Island [3]. CropLife Canada strongly believes that plant science technologies, paired with a timely and science-based regulatory system, can help farmers address challenges such as increased demand for food while preserving soil health and biological diversity, both in Ontario and globally.

As mentioned above, the global population is expected to exceed 9.5 billion by 2050. To meet this demand in an environmentally sustainable fashion means that healthy agricultural soil will become more important than ever before. The technologies that our members have developed have played a critical role in facilitating the adoption of beneficial land management practices and we anticipate remaining at the leading edge of sustainable agricultural innovations in the future. The development and adoption of soil best management practices using innovative plant science technologies will continue to increase the productivity of Ontario’s existing farm land, reducing the need to bring additional land in to production, and thus contribute to healthier agricultural soils in the province.

Conservation tillage Canadian farmers have increasingly adopted conservation tillage as a method of cutting soil and water losses by leaving a protective crop residue on the soil surface. Over the last five years, the total hectares of land prepared for seeding using conservation tillage has increased by 5% in Ontario and 14% across Canada [4]. Not only do such practices retain carbon dioxide captured in the soil [5-7], conservation tillage also improves soil health and moisture retention, reduces soil erosion and runoff [8] while providing economic benefits for farmers.

Advances in plant science innovations, such as seed treatments and herbicide-tolerant crops, are facilitating the adoption of conservation tillage [9]. The development of these technologies has given farmers the confidence that weeds can be controlled economically without relying on conventional tillage. CropLife Canada is proud that plant science innovations developed by our members promote the adoption of sustainable farming practices.

CropLife Canada is strongly supportive of efforts put forth in the Strategy to better understand conservation tillage practices and develop strategies to promote and enhance them.

Climate change Advances in plant science technologies are helping the agriculture community mitigate and adapt to climate change. For instance, plant scientists are developing drought-tolerant varieties of crops that use water more efficiently during drought conditions. On the other end of the spectrum, crops are being developed which are tolerant to partial or complete submergence in water, an attractive characteristic for future global food security concerns.

Over the course of the past 25 years, reductions in tillage owing to the use of plant science innovations have reduced GHGs by about 4 million tonnes per year [3]. On an average annual basis, the broad array of plant science innovations result in a reduction of 29 million tonnes of GHGs per year compared to agricultural production without plant science innovations [3]. The Government of Ontario has outlined ambitious GHG reduction targets to help mitigate the impact of climate change. The agricultural community in Ontario will play a significant role in helping to meet these targets by reducing GHG emissions in the province. However, if farmers do not have timely access to plant science technologies, such as seed treatments, we could see a reduction in the prevalence of conservation tillage as growers are forced to revert back to conventional tillage and less efficient associated plant protection practices. This would lead directly to increased losses of soil by wind and water erosion, as well as increasing the net emission of organic carbon from soil – an outcome that would run counter to the Ontario government’s goal of reducing GHG emissions across the province.

Research, innovation and investment Investments in agricultural research and development will play a critical role in meeting demands for increased food production in the face of rising temperatures, resource scarcity, and the increased frequency of extreme weather events. As stated in the Strategy, the “innovative spirit needs to be nurtured through policies and programs”. CropLife Canada strongly encourages the science-based approach put forth by OMAFRA in this strategy and we agree that innovative farmers often lead the way. By way of example, CropLife Canada’s member companies globally invest about 10% of profits into plant science technology research and development; a percentage comparable to that seen in the pharmaceutical sector. For Canada, and Ontario, to realize the benefits of this investment, we need to maintain our strong tradition of science-based regulation.

Health Canada’s Pest Management Regulatory Agency (PMRA) and the Canadian Food Inspection Agency (CFIA) are responsible for reviewing plant science innovations (pesticides and new plant varieties) before they can be registered for sale or use in Canada to ensure they are safe for human health and the environment.

CropLife Canada cautions that prescriptive regulatory burdens not based on rigorous scientific evaluation and assessment, especially those imposed without the support of the agriculture community, run counter to the “innovative spirit” and cooperative formula for success, having the net effect of stifling investment and innovation in Canadian agriculture.

As such, CropLife Canada recommends a thorough review of the mandate and practices of the Ontario Pesticides Advisory Committee (OPAC). While acknowledging the jurisdictional authority of the province to establish such a body, we submit that OPAC could work more collaboratively with the various sectors of the economy over which it regulates the availability of new plant science innovations. Timely access to these technologies, reviewed and approved by the PMRA and the CFIA, would enable the agriculture sector to put them to use in improving soil health and plant biodiversity. CropLife Canada and its member companies would be pleased to contribute to this dialogue.

A path forward The agricultural stakeholder value chain has a long and successful history in promoting and enhancing environmental sustainability. In addition to our commitment to developing plant science innovations, we are also proud of our work in, for example, obsolete pesticide disposal and container recycling through our sister organization CleanFARMS. We are, and will continue to be, strongly committed to the vision outlined in the Government of Ontario’s draft strategy document and look forward to working with the Government to ensure that Ontario’s soils remain healthy and productive for generations to come.

References Cited 1.Clearwater, R.L., T. Martin, and T. Hoppe, Environmental Sustainability of Canadian Agriculture. Agri-Environmental Indicators Report Series, Report #4, Agriculture and Agri-Food Canada, Editor. 2016: Ottawa, ON. 2.Food and Agriculture Organization of the United Nations, How to Feed the World 2050: High Legel Expert Forum, Agricultural Development Economics Division, Editor. 2009, Food and Agriculture Organization of the United Nations: Rome, Italy. 3.RIAS Inc. The Value of Plant Science Innovations to Canadians. 2015. 1-65. 4.Statistics Canada, Table 004-0010 - Census of Agriculture, selected land management practices and tillage practices used to prepare land for seeding, Canada provinces, every 5 years. 2017, Statistics Canada: Ottawa, ON. 5.Boame, A.K., Zero tillage: a greener way for Canadian farms, Statistics Canada, Editor. 2005, Statistics Canada,: Ottawa, ON. 6.Abdalla, M., et al., Conservation tillage systems: a review of its consequences for greenhouse gas emissions. Soil Use and Management, 2013. 29(2): p. 199-209. 7.Reicosky, D.C. and D.W. Archer, Moldboard plow tillage depth and short-term carbon dioxide release. Soil and Tillage Research, 2007. 94(1): p. 109-121. 8.Derpsch, R., et al., Current status of adoption of no-till farming in the world and some of its benefits. International Journal of Agriculture and Biological Engineering, 2010. 3(1). 9.Fawcett, R. and D. Towery Conservation Tillage and Plant Biotechnology: How New Technologies Can Improve the Environment By Reducing the Need to Plow. 2003. 1-24.

[Original Comment ID: 211619]