Re: Canada-Ontario Action…

Re: Canada-Ontario Action Plan for Lake Erie (EBR Registry Number: 012-9971)

Dear Ms. Malhotra,

The Ontario Fruit and Vegetable Growers’ Association is a not-for-profit association that advocates on behalf of the province’s fruit and vegetable farmers, including greenhouse growers. Over 125 different fruit and vegetable crops are grown in Ontario with an estimated annual farm gate value of $1.6 billion according to 2013 statistics. OFVGA appreciates the opportunity to provide comment on the Canada-Ontario Action Plan for Lake Erie consultation.

OFVGA is in support of the need to have a coordinated effort for phosphorus reduction in the Lake Erie basin. As a member of the agricultural community, we have made the commitment to work in collaboration on phosphorus reduction in the Great Lakes. Case in point: OFVGA is a member of the Grow Ontario Together initiative – a group comprised of agriculture organizations that seek to take action in order reduce nutrient loading. We know that phosphorous levels are higher than they should be and farmers are willing to be part of the solution to this problem.

Ontario fruit and vegetable farmers are taking action. Here is a list of just a few examples of the proactive measures that farmers are currently doing:

•Practicing 4R Nutrient Stewardship - an approach that focuses on the scientific principles of applying the RIGHT SOURCE of plant nutrition, at the RIGHT RATE, at the RIGHT TIME, and RIGHT PLACE to improve nutrient use efficiency to reduce any potential nutrient loss into the environment.
•Investing in Modern Infrastructure – growers are always looking for new technologies to make improvements and do their part to contribute to a sustainable economy and food system. OFVGA highlights some of these examples in point 7 of our response.

In addition, as the voice of the province’s editable horticulture sector OFVGA has supported The Great Lakes and St. Lawrence Cities Initiative in partnership with Ontario’s largest general farm organization – Ontario Federation of Agriculture. As well OFVGA is in a unique position to communicate to the masses i.e. to Canadian and Ontario farmers through The Grower, Canada’s premier horticulture publication to share information about industry best practices and new tools that growers can use in order to continue to be good stewards of the land through sustainable farm practices.

Feedback based on the questions outlined in section iv of the consultation:

OFVGA would like to put forward the following comments and suggestions in support of The Canada-Ontario Draft Action Plan. Questions 1 and 2 are discussed earlier within this document with respect to our overall input and intent to participate in The Action Plan. To reiterate, we plan to continue collaboration with The Grow Ontario Together initiative and do our part to reduce phosphorus loadings into Lake Erie.

3. When looking to regional and local planning authorities during the implementation process, we ask to continue and be included in the decision making process and be consulted to ensure that targets are attainable for fruit and vegetable growers.

4. We foresee two barriers to reducing phosphorus loadings into Lake Erie. The first is taking into account severe weather events that play a significant role in phosphorus loading. The second relates to equipping all farmers not just those in the watershed with the tools in order to implement measures on their farm. OFVGA asks that environmental remediation funds be earmarked to help farmers’ access technologies that allow them to engage in practices that reduce and manage phosphorus loadings.

5. As noted in our opening remarks, we strongly believe in the importance of collaboration. OFVGA along with several key agriculture industry partners have taken leadership through our commitment and participation in The Grow Ontario Together initiative – a group of agricultural organizations that seek to take action in order to reduce phosphorous loadings. We also welcome collaboration with other non-agriculture stakeholders as we tackle this issue together.

6. We too agree for the need to track progress in achieving Lake Erie phosphorus load reduction targets. OFVGA believes that proper benchmarks need to be created in order to monitor key indications that are directly correlated to the health of Lake Erie. Some of these key indicators could include things like number fish stock, increased wildlife habitat and oxygen levels in the lake.

7. OFVGA would like to see the efforts of The Great Lakes and St. Lawrence Cities Initiative continue – this approach is needed to manage phosphorus run-off issues. In addition, the continued support for managed wetlands as buffer zones is a good example of what can be done at a local level. Farmers are already leading the way through technologies to reduce farm wash water. There has been significant research examining potato wash water treatment and in general reducing water use. One example of a technological advancement that has been implemented on farm includes, Sunrise Potato in Alliston, Ontario. A good overview of wash water management on horticulture farms can be reviewed by visiting here: http://www.hmgawater.ca/uploads/1/7/2/8/17281360/ofvc_poster_speranzini… (The academic poster was presented at the Ontario Fruit and Vegetable Convention). Furthermore, looking to the vegetable greenhouse sector, the implementation of “closed loop” – a hydroponics system and the attachment to water treatment facilities at the municipal level are all examples of technological initiatives that have been put in place by growers to manage and / or treat phosphorus run-off.

OFVGA would once again like to thank the government for the opportunity to provide comment on the Action Plan, and we look forward to continue to work in collaboration with stakeholders to do our part in reducing phosphorus loadings into Lake Erie.

[Original Comment ID: 209401]