Environmental Issues Ammonia - AToxic Substance?
by Cam Dahl, Executive Director, Grain Growers of Canada
There is little question
that changes to environmental policies over the next few years are going to have
a significant impact on the way in which you farm.
Farmers from across the country are going to have to become increasingly engaged
in environmental policy discussions.
Many farmers are concerned they will incur a disproportionate level of the cost
burden of new environmental initiatives.
These policies are being undertaken to benefit society as a whole. Producers'
should not see their net incomes fall because of these undertakings.
Recent decisions by the Government of Canada surrounding the issue of ammonia
provide a graphic illustration of why farmers and farm organizations must pay
increasing attention to environmental questions.
In 2002, the Government listed ammonia dissolved in water as a toxic substance
under the Canadian Environmental Protection Act. This action was largely taken
in response to the problem of ammonia being put into the watershed through municipal
wastewater. However, no distinction was made between the essential agriculture
uses of ammonia and municipal pollution. Now grains and oilseed farmers applying
many chemical or natural fertilizers may be caught in a regulatory web intended
to cover other purposes.
In 2003, the federal department of the environment went one step further and listed
gaseous ammonia as a toxic substance.
There is some evidence that the presence of ammonia in the air can contribute
to the formation of smog. However, the scientific evidence is not conclusive.
Regulations under the Canadian Environmental Protection Act must be founded on
a science-based risk assessment. The science presented so far does not justify
listing “gaseous ammonia” as toxic because many questions remain unresolved
concerning the role of ammonia in smog formation. The majority of the ammonia
released to the atmosphere comes from sources other than agriculture. Regulations
under the Act should have been crafted to target the specific problem, industrial
emitters, not agriculture. However, once again, no provisions were made for agriculture's
unique circumstances. Once again farmers could find themselves facing restrictive
regulatory controls designed to cure a problem caused outside of our industry.
The federal department of the environment has stated that they would prefer voluntary
measures to control the releases of ammonia into the air and water. However, the
department has the power and authority to bring down restrictive regulations if
their internal objectives are not being met. We are concerned that the farmers'
needs will be overlooked in this process, just as they have been overlooked when
the recent policy changes were made.
The use of ammonia as a fertilizer is essential to the production of grains and
oilseeds in Canada. The unintended curtailment of this necessary component of
production will harm the competitiveness of our industry at a time when farm families
can least afford to bear additional cost burdens. It is the Grain Growers of Canada’s
contention that ammonia used as a nutrient in crop production does not belong
in the package of substances that are listed as contributing to the formation
of smog, nor should it have been listed as toxic when dissolved in water.
Like all Canadians, grains and oilseed farmers are supportive of measures that
will reduce smog and the negative impacts of air and water pollution. In fact,
the grains and oilseed sector has already contributed a great deal to better air
and water quality. Improvements to management practices that have reduced the
consumption of fossil fuels and significantly improved nutrient management practices
are just some examples.
Do not the overwhelming majority of grains and oilseed farmers undertake managment
practices that maximize the utilization of nitrogen by crops? Do not the majority
of farmers attempt to minimize the use of tillage and thereby minimize the use
of fossel fuels? The fact is that modern agricultural practices have helped to
minimize the release of ammonia (and other forms of nitrogen), carbon dioxide
and other pollutents into the environment. Improvement to management practices,
including the storage and application of crop nutrients, will continue to advance
and will contribute to enhanced air and water quality across the country. It is
important that governments recognize these important positive contributions that
have been made in the past by our industry and acknowledge the growing contribution
of farmers to environmentally sound business practices.
Similar principles apply to the many other environmental debates that are before
us. For example, the positive actions previously implemented by producers that
have resulted in reducing greenhouse gas emissions and sequestering of carbon
must be taken into account when developing programs to implement the Kyoto agreement.
Unfortunately, the agriculture industry has not yet had significant success in
convincing the government that this is the right approach.
The agriculture industry has the ability to make even greater contributions to
environmental initiatives. Increased use of ethanol, bio-diesel, and other bioproducts
present just a few examples of areas that will yield positive economic benefits
for farm families while helping Canada meet its environmental commitments.
The Grain Growers of Canada will continue to be heavily involved in these debates,
pushing the Government of Canada to consider the needs and contributions of Canadian
farm families.
Members of the Ontario Corn Producers’ Association have made a significant
positive contribution to this important national debate. The Grain Growers of
Canada will continue to work closely with your organization to advance the best
interests of farmers from coast to coast.
