Section 4.0 Relationship to…

Section 4.0 Relationship to Source Water Protection Plans Is it intended that only NASM land application be restricted according to key water vulnerability indicators, or will land application of agricultural fertilizing materials such as manure and inorganic fertilizers also be restricted. If the intention is to only restrict application of NASM, then such a restriction is unjustifiable, since presumably source waters would be equally if not more vulnerable to contamination from agricultural fertilizing materials compared to NASM. If source waters are considered not to be at risk from agricultural fertilizing materials, then they are clearly not at risk from NASM. Section 6.1 Sites (farms) that receive NASM under the proposed framework It is understood that the proposed field nutrient management plan for land application of NASM will replace the existing application for a Provisional Certificate of Approval for a soil conditioning site. Will an application for a field nutrient management plan require the same supporting information as a Provisional C of A application? Will the approval process be similar the existing process for Provisional Cs of A and which ministry will be responsible for issuing the approvals? In our experience, the approval of Provisional Cs of A has often taken in excess of 4 months, in some cases over 6 months, depending upon which MOE District or Area the approval falls under. Changes in regulation that either do not improve the processing of site approvals or slow the processing of site approvals would not be considered an improvement. 20.0 Criteria for odour annoyance The proposed criteria for odour annoyance is subjective and as such should be reconsidered. Odours are a reality of biosolids just as they are a reality of manures generated by agricultural operations. Odours can be managed through prompt and effective incorporation, which means that they are minimized, but not eliminated. Residents who live in rural areas surrounded by modern agricultural operations cannot be made to expect that there will be no odours and by instituting the criteria for odour annoyance, the Province may raise expectations among rural residents with respect to non-NASM odours as well as unrealistically restricting legitimate land application of NASM. Section 21.1 Calculation of maximum application rate based upon nitrogen, phosphorous, metals, sodium, fat, oil and grease (FOG) and boron addition. 1.Phosphorous The formula for the calculation of plant available phosphorous (PAP) and the proposed maximum permitted addition of 390 kg P2O5 per hectare will result in a significant reduction in the 5 year application rate of City of Ottawa biosolids while at the same time potentially depriving phosphorous deficient soils of a source of phosphorous and depriving co-operating farmers of the full nutrient benefits of City of Ottawa biosolids. In our opinion, there are two key issues pertaining to phosphorous in municipal biosolids applied to agricultural land: 1-the risk of phosphorous loss to surface water, and 2-the plant availability of phosphorous in municipal biosolids It is understood that limits on nitrogen and phosphorous are necessary to prevent contamination of surface and ground waters. In the case of phosphorous, nonpoint loading to surface waters can result in eutrophication. The transfer of phosphorous to surface waters depends upon the type of phosphorous bearing material being applied to the land, the rate and timing of the application, the frequency and timing of rainfall, the topography and the presence or absence of a buffer zone. Withers et al(1) found that the lowest risk of phosphorous loss to surface water was from dewatered anaerobic biosolids, compared to triplesuperphosphate, liquid cattle manure and liquid anaerobic biosolids. This is because the phosphorous in dewatered biosolids in particular and in biosolids in general, tends not to be soluble. This fact coupled with 20 meter minimum buffers from surface water, depending upon the slope of the field towards surface water, means that the risk of surface water contamination from land application of NASM biosolids, especially compared to land application of other typical agricultural sources of phosphorous, is very low. The plant availability of biosolids phosphorous depends upon what was used to flocculate the phosphorous and the soil phosphorous availability (background concentration)(2). Soils that are phosphorous deficient will show greater changes in plant available phosphorous following application of biosolids than soils that have a high phosphorous content and iron flocculated phosphorous is not rapidly exchangeable (3). In 2007, we collected 66 soil samples from farms in West Carleton, Matilda and Edwardsburg. The mean sodium bicarbonate extractable phosphorous was 13 mg/kg, which is rated as ‘low’ Ultimately, the NASM phosphorous application rate should not be based upon an arbitrary maximum and expected plant uptake but rather should take into consideration background soil phosphorous. In areas where there has been eutrophication as a result of non-point source phosphorous from agriculture land, it is the result of long term land application of animal manures the contain relatively high concentrations of soluble phosphorous, which in some cases has saturated the soil’s capacity to hold phosphorous and in other cases has migrated directly to surface water when manure travels vertically through preferential pathways in the soil column into sub-surface tile drains. Phosphorous in municipal biosolids is not readily soluble and therefore presents a very low risk to surface water contamination while at the same time will act to slowly build up background phosphorous. 25.1 Temporary storage of solids non-agricultural source material Prior to the Nutrient Management Act, storage of dewatered biosolids was permitted in a temporary field storage site for not more than 90 days, on a case by case basis. Under the Nutrient Management Regulation, temporary field storage is permitted for no more than 10 days. Under the proposed improved regulatory framework, storage would be permitted for not more than 24 hours. Short term field storage, in fields where such storage is appropriate, is an important tool for maximizing the beneficial use of dewatered biosolids. In some cases storage cannot be avoided, in the event that material is hauled to a field with the intention of spreading it, but due to weather factors, it cannot be spread as planned. What is the rational for reducing the length of storage from 10 days to 24 hours? 25.3 Storage of non-agricultural source material in permanent nutrient storage facilities If a farm has a permanent nutrient storage facility, such as a manure tank that is not in use why is storage limited to 14 days? Reference List (1) Withers PJA, Clay SD, Breeze VG. Phosphorus transfer in runoff following application of fertilizer, manure, and sewage sludge. Journal of Environmental Quality 2001; 30(1):180-188. (2) Frossard E, Sinaj S, Zhang LM, Morel JL. The fate of sludge phosphorus in soil-plant systems. Soil Science Society of America Journal 1996; 60(4):1248-1253. (3) Frossard E, Sinaj S, Dufour P. Phosphorus in urban sewage sludges as assessed by isotopic exchange. Soil Science Society of America Journal 1996; 60(1):179-182. City of Ottawa Robert O. Pickard Environmental Centre

[Original Comment ID: 104726]