Agroecology as a Basis for Irrigation Strategy

By Trudy White, Iris

One would expect that any irrigation or soil improvement strategy being developed for our Island would be grounded in the most current scientific knowledge on soil health and would address the very serious issues of declining soil biodiversity and pesticides in soil, water, and sediment.  Yet this irrigation strategy discussion document does not even mention the words biodiversity or pesticides.

Science clearly tells us that protecting and restoring soil biodiversity is critical for soil regeneration and resilience and also for sustaining our water cycle.  But the document fails to mention “increasing biodiversity” even in its sections about Improved Environmental Benefits or Soil Health.

Perhaps this is because PEI currently does not assess soils for biodiversity.  The SHIP program uses a soil respiration test to assess soil microbial activity and the proposed irrigation strategy proposes this could be tied to future water permits.  But this test simply measures the amount of CO2 (respiration) released by aerobic organisms from a soil sample.  It is not an assessment of biodiversity.  Depleted soils – even those with very little soil biodiversity – still release CO2 from biological activity – that activity coming primarily from soil bacteria and pests. 

Soils that are lacking biodiversity also need more fertilizer and pesticides because their natural capacity for nutrient recycling is stalled and pests are more likely to attack stressed plants. Those soils are also more prone to erosion.  Unless actual soil biodiversity is assessed and monitored, it will be very difficult to determine if soil health is improving and use this as a condition for granting water use permits.
Also nowhere within the proposed strategy document do we find the words “reducing pesticides”.  Pesticides are designed and used to kill pests but they also kill many non-target organisms and can impact entire ecosystems.  Pesticides vary in their ability to move within soils and into ground water and streams.   Irrigation has the potential to increase the movement of some pesticides and expand their area of impact.  An irrigation strategy that does not address the use and the movement of pesticides in soil and water seems irresponsible and incomplete.

The Food and Agriculture Organization of the United Nations now recommends using an “agroecology” lens to evaluate agriculture methods, policies and new technologies.  Some PEI farmers are already using agroecological methods and best practices on their farms and many more are ready to transition.  This irrigation strategy discussion document falls short oin supporting those farmers and moving agriculture in that more sustainable direction.  This is a missed opportunity.  I note that several other submissions have made excellent suggestions for how the strategy can be improved through better governance, permit requirements, and monitoring.

I believe PEI’s proposed irrigation strategy should be re-evaluated using the principles and scientific knowledge of agroecology.   If it survives that re-evaluation, it should be re-written to reflect those principals.  The future of our Island’s water and soil depend on it.

PEI Chapter of Council of Canadians Responds to Irrigation Strategy

There is no vision nor much hope offered (in this Irrigation Strategy document) for the protection of PEI’s water and land. As Islanders, like the rest of the world, we face the most serious crisis in history – the climate crisis – yet, we are presented with a document that ignores the crisis and gives a ‘license’ for the continuation of an industrial model of farming controlled by very powerful corporate interests.  A model of farming by all accounts that is not sustainable and is doomed – and a major contributor to the climate crisis. 

It’s a  license under the guise of ‘fairness’  given to an industry that continues to poison our groundwater, our estuaries, our land, and air with huge amounts of chemical fertilizers and pesticides. 

According to the Department of Environment, Energy and Climate Action nitrate contamination from fertilizers is pervasive in the province and is dominated by the potato sector. 

Nitrate contamination in drinking water is very common in PEI, particularly in areas of the province with high concentration of potato production which is now almost everywhere. But nowhere is the concentration of nitrates in our drinking more prevalent and problematic than in the East Prince and central Queens area of the province. Water reports for example from the City of Summerside, reveal very high levels of nitrates and other chemicals in its water supply. And Summerside is not alone. We know many private wells in the province exceed the legal limits of nitrate contamination.

The federal limit of 10 milligrams per liter, or mg/L, equivalent to parts per million, for nitrate in drinking water, was set in the 1960s has not been updated. This standard was developed to prevent acute cases of methemoglobinemia, which causes an infant to suffer from oxygen deprivation in the blood after ingesting excessive nitrates.

More recent studies which have been published have found increased risk for other troubling health outcomes at nitrate levels significantly below 10 mg/L. A comprehensive scientific review of nitrate drinking water concentrations and related impacts on human health showed strong evidence of an increased risk of colorectal cancer, thyroid disease, and neural tube defects at nitrate concentrations in drinking water below the current legal limit of 10 mg/L.

It is important to note that Danish researchers have found an elevated risk of colorectal cancer associated with drinking water concentrations of just 1 mg/L – tenfold lower than the Canadian drinking water standard. A study conducted in Spain and Italy found an increase in colorectal cancer risk at 1.7 parts per million, or ppm, of nitrate. As well, recent studies conducted in the U.S. found greater incidence of colorectal, ovarian, thyroid, bladder, and kidney cancers among people exposed to nitrate from drinking water at levels half the federal standard. 

 As well, there is growing evidence of the damage to human and animal health when both chemical fertilizers and pesticides are considered in combination.

It is astounding that the PEI government continues to encourage and financially support a system of agriculture that is corporate-controlled, offers little by way of food security for the province, is hugely environmentally destructive, and as noted above, a human and animal health hazard.

The local Council of Canadians is asking why should an industry so destructive to human and environmental health be allowed supplemental irrigation? Especially since this is the one industry by government’s own scientific evidence is the culprit behind the contamination of our groundwater – the only source of drinking water for Islanders.

Given these very considerable constraints, and as the document offers no standards in what constitutes healthy soil, no model for real democratic governance of groundwater management, the local Council of Canadians gives a thumbs down to this Irrigation Strategy proposal. We also believe that the proposed ‘Irrigation Strategy’ is another move by the present government to hand over control of our groundwater to corporate interests.

We should point out that the local Council of Canadians has been calling on PEI governments over the past few years to introduce a just transition plan from an industrial mostly monoculture model of agriculture to a more sustainable and healthy food growing system – one that is free of commercial chemical fertilizers and pesticides.

The local Council of Canadians believes we need a system of agriculture in the province that is socially and ecologically just where true fairness plays a role in the growing and distribution of food and that accounts for real environmental and social costs.

Guiding Principles for an Irrigation Strategy

By Don Mazer, on behalf of the Coalition for the Protection of PEI Water

The Irrigation Strategy (IS) document is the culmination of what began as the exemplary process of public consultation that resulted the Water Act. This process reflected widespread public opposition to ending the moratorium on high capacity (HC) wells. It is ironic that the outcome of this extended process was a plan to enable the return of HC wells.  It is unfortunate that this decision seemed to be based almost entirely on the will of the minister,  who seemed to require little evidence, and had little interest in meaningful consultation with citizens or even his own standing committee.

The result is an ‘irrigation strategy` that offers limited opportunities for meaningful input from Islanders. This document should have been the result of a public process that engaged citizens. Rather, it was developed quietly and internally by the department and its bureaucrats and whomever they chose to consult with. This did not include our group, the Coalition for the Protection of PEI Water. Our coalition includes a broad range of environmental, watershed and socially concerned groups and individuals. From the first days, we have been deeply involved in the process of developing the Water Act, and acknowledged by a previous Minister in the legislature for its important contribution to the Act.  We are concerned why a group like ours with such a longstanding commitment to PEI water would not be included in such consultations.

 And now, the public only gets a very limited opportunity to respond to the IS: only anonymous online comments, on the way to a final strategy, with no further opportunities for comment.  This is not meaningful consultation in any sense. A good faith consultation would provide the opportunity for citizens to be seriously heard and the potential to influence decision making.  This document continues to illustrate that this government has little appetite for listening to concerned and well informed citizens.

This is a major shortcoming of the IS which needs to be addressed. It  raises concerns that the IS is being shortracked to be put into place to meet the needs of  particular agricultural interests who might want HC wells, perhaps in time for the next growing season. But we are all stakeholders when it comes to water.  The public interest and the commitment to healthy and plentiful water and healthy ecosystems must be central to any policy.

It is important to take a step back to reframe and broaden this proposal, and to think of irrigation as an element of a broader water policy. And as the Watershed Alliance wisely advised, an irrigation strategy must be guided by some key principles.

 First, we need to be mindful that water is a common good and a public trust that supports the life and health for all beings, human and nonhuman, and not just a  resource for us to use. Contrary to the assumptions in this document, it is a limited resource, and we should be thinking more about much how much water we can leave, rather than how much we can take.  Conserving water, and minimizing the need for water should be a guiding principle of this policy.

Second, any policy must be guided by the principle of not only protecting the quality and quantity of water and the health of our soils, but improving them. We have significant problems in our waters: many years of high nitrate levels, pesticide contamination, ongoing anoxic conditions, fishkills. The organic content of our soil has been seriously depleted and been in precipitous decline over many years.  This policy needs be a means of enhancing environmental health, and support the efforts a number of farmers are making to improve soil. Access to water for irrigators should be tied to such improvements on specific, measurable indicators of the health of our lands and waters.

We can no longer afford to permit water to support practices that don’t contribute to such improvements.

It is shocking at this present moment that a proposal coming from the Department of Environment is almost completely inattentive to the climate emergency.  In fact, the only reference  is the hopeful comment that climate change may actually provide more available water for recharge.  But of course, not much water will penetrate into an aquifer if it runs off the soils of uncovered fields, that lack the organic content to absorb the increasingly big storms we anticipate. The rivers will continue to run red with siltation.

And so, third, it is imperative that this policy must be guided by the principle of addressing climate change. Agriculture is a major contributor to climate change, estimated to account for 30% of global emission of greenhouse gases. Significant reductions in emissions are required by 2030 to stabilize rising global temperatures. The IS policy needs to be part of the climate solution. We cannot afford to permit the irrigation of lands that are contributing to the climate emergency.

It is clear that practices that are integral to much agricultural practice on PEI contribute to climate change. Nitrates are a major ingredient of fertilizers and pesticide.They  are the major source of agriculture’s considerable contribution to  emissions through conversion to N2O, a greenhouse gas far more dangerous than C02. The sporadic use of cover crops and the low organic content of our soils also are major contributors. . ( (   data on PEI fertilizer, pesticide use could be useful  here, if anyone has access to data.).

Agriculture can contribute to climate change solutions by focusing on the vital role of soil in carbon sequestration. “Good farming should mean ongoing carbon sequestration. Agricultural land should be a carbon sink. But as practiced now — with massive reliance on fossil fuels, on soils stripped of organic carbon — industrial farming is a major contributor to the global crisis of atmospheric carbon. “.

It is encouraging that the IS identifies improving organic content as one of the required elements for irrigation permits.  Cover crops, and no till farming are other practices that are helpful to carbon sequestration that could be a part of this policy. PEI could follow the lead of Alberta and Saskatchewan who have programmes that reward farmers for carbon sequestration.

To meaningfully address climate change (and the other issues of water and land), agriculture needs to do things differently. There would be far less carbon to sequester if there were fewer nitrogen inputs.  On PEI, half of agricultural emissions are associated with fertilizer use.  But the IS is silent on the amounts of fertilizer and pesticide use in PEI soils, or reducing their use, or how farmers might be rewarded by actively combating climate change.  Rather it places its faith in hopes that irrigation, “precision agriculture” and even climate change itself will aide the more efficient uptake of nitrogen by plants. When you consider the many years of high levels of nitrates in drinking water and watercourses, there seems to be little data to support this optimism.

On the climate change calendar, we can no longer to continue to do more of the same, and try to do it a little bit more/better. There are targets we need to meet as global citizens.

Consider transportation. We are almost completely reliant on cars fueled by gas.  By 2035, the sale of new gas cars will be banned in Canada. The fuel efficiency of gas cars is no longer a viable direction for government policy. The climate can’t afford them. We know we need to do things differently, moving ourselves with  EVs, hybrids, biking and walking.

The IS policy needs to be a starting point for change, for charting a course where agriculture will be part of the solution to the climate crisis, and this requires reducing its dependency on nitrates. There are many resources that provide approaches and directions for such change. Regenerative agriculture, agroecology and organic agriculture offer methods to help farmers make a good living, while addressing climate change, and enhancing the health of land and water.

Fourth, public engagement should be a key guiding principle of this policy.  The IS introduces the important idea of Water Governance (WG) which provides an excellent opportunity for such involvement.  We believe that WG should be guided by a community based-participatory model, where consultation, collaboration and public input into decision making are key ingredients. We are all stakeholders when it comes to water.   It is critical that members of boards be representative of the broad range of interests and people in the community, and include Indigenous people, environmental and watershed groups and other citizens, along with representatives from farming organizations. Such boards need to be entrusted with the authority to deliberate and make meaningful decisions on an ongoing basis.

It is ironic that a proposal for Water Governance emerges from what has essentially been a bureaucratic process (a top down” Water Management” approach) with limited opportunity for public participation. If the government is serious about including citizens in governance, the best place to start is to provide meaningful  opportunity for the public to  react and comment about the revisions to this IS strategy and to potentially impact the final policy. It’s important for you to take steps to restore public trust in the idea that government values the views of its citizens in regards to water.

This is a critical moment in protecting and enhancing the health of our land and water, addressing climate change, and for restoring public trust and engagement. We urge you to take this opportunity as to instigate the change that we require.

A Framework for Water Governance

By Gary Schneider, Environmental Coalition of PEI and member of the Coalition for the Protection of PEI Water

The province’s new Irrigation Strategy is a document that all water users – not just those who use irrigation in whatever form that takes – should take a long, hard look at.  The development of the Water Act started out as an exemplary template for meaningful public participation.  Unfortunately, over time, the process has become less and less transparent and responsive.

One way to get things back on track is to return to sound participatory processes. Any strategy is only as good as its implementation. The water governance body, an independent, arms-length, representative body to ensure proper implementation, is an idea that has been repeatedly brought forward by the Coalition for the Protection of PEI Water and other stakeholders.  The Irrigation Strategy pledges that “In addition to the administration of permits being delivered by a central body, irrigation will also be overseen by a central advisory board.  This board will be tasked with ensuring the continuation of strategy finds the balance between environmental protection and commercial usage.  This board will consist of users, conservation groups, senior government officials and other key stakeholders.”

How do we make this body truly representative?  The provincial Round Table on Resource Land Use and Stewardship had representatives from a variety of sectors – agricultural, tourism, conservation, forestry, aquaculture, municipalities, recreational fisheries, etc.  This body worked together and came up with some great recommendations that have become part of our way of life.  Unfortunately, many others were not fully adopted, or not adopted at all, leading to continued environmental degradation.

Another multistakeholder group recently advised the Federal Minister of Environment and Climate Change Canada on the Impact Assessment Act.  This body had 18 seats – six representing heavy industry, six from various Indigenous organizations, and six from environmental and conservation groups. While discussions were often challenging, the diversity of viewpoints and interests ensured a better act.  

If we really want an inclusive, responsive and effective water governance board, we can do it.  The following sectors should be represented: municipalities; large-scale potato growers; smaller-scale potato growers; other farmers growing different crops; dairy and beef producers; organic growers; Indigenous groups; watershed organizations; the aquaculture industry; recreational fishers; researchers in the areas of water, climate change, and improving soil health; youth; conservation organizations; and tourist operators. 

I’m certain that I have missed some voices, but the idea would be to have all sectors present at the table participating in an open and transparent process.   This vital board, and the accompanying local watershed advisory groups, must also have real authority to ensure that permit holders’ commitments to water conservation, water quality (including reduced nitrate loading and pesticide use), soil improvement, and environmental protection are met, and to trigger enforcement if they are not.

Only then will all sectors feel as though they have been represented around the table.  Only then will our water resource receive the attention and protection that it so desperately needs, in order to be available for the public, our industries, and wildlife today and long into the future.

Two steps back on P.E.I. Water Act

Public engagement holds little traction with the current P.E.I. government

The Guardian (Charlottetown)- 26 Nov 2021

BOYD ALLEN is on the board of the Citizens’ Alliance of P.E.I., a member organization of the Coalition for the Protection of P.E.I. Water.

In May of 2016 the P.E.I. environmental advisory committee released a comprehensive report entitled: Water Act – Public consultation report. It was 58 footnoted pages long including indices and glossary. It collated findings from the first phase of public consultations on the Water Act from July 2015 to January 2016.

This process offered multiple opportunities and methods for private citizens and organizations to present their opinions. The response was extraordinary. There were 50 presentations at the various public community meetings and 12 one on one consultations between the EAC and concerned organizations. Every submission to the EAC during this time was made easily available online.

Phase 2 of this clearly structured process was the creation of a draft Water Act and thence a second round of public consultations. The final phase was the creation of the act, tabling it in the legislature and opening it for clause by clause debate. It became law in December 2017. This deservedly was lauded as a template for public engagement in the creation of legislation in Canada.

Five years and four environment ministers later, in mid-October 2021, Irrigation Strategy – A document for review, comment and discussion was released by government. This document, for many involved in the process, represents the rubber hitting the road with the Water Act. There was no photo-op nor explanatory press package. There was no call-out for responses. It is 14 pages in length. There are no cited references nor support documents.

The strategy is built on a foundation of broad assumptions: There is an infinite supply of water on P.E.I.; climate change will enhance this; the entire agricultural industry requires much more supplemental irrigation; irrigation promotes better nitrogen uptake and therefore less leeching into the groundwater; safe environmental stream flows are easily modelled from existing data on a watershed by watershed basis. Either the province can redeploy/hire the skilled workforce necessary to monitor, administer and/or enforce this proposed suite of regulations or it is prepared to let the industry police itself.

There was no forum offered by its authors to discuss this strategy nor question the suppositions that support it.

The standing committee on environment was supposed to provide both oversight on the development of this strategy and be the access point for the public to have their concerns addressed. The relationship with the current minister and his senior managers with this committee has been described by some observers as ambiguous, and by others as contemptuous. Minister Steven Myers made this clear when he stated, “At the end of the day it will be the experts in my department who I will lean on to yay or nay.”

When considering the undertaking of a presentation to this committee you’d have to question whether it was worth the considerable effort involved in so doing. Many chose not to.

The traction that public engagement holds with the current government is made evident under the heading “Timeline” in this document: “The Department intends to consider all feedback during this calendar year and will make revisions soon after. This version of the strategy would be final and implemented.” Government has decided that the names of those who submit comments online will not be disclosed. As of Nov. 23, there is a total of one submission noted on the webpage.

The heady days of meaningful public consultation, collaborative decision-making and transparent governance seem to have fallen out of favour with the King government. Sadly, the foundational ideas, embedded in the Water Act: the precautionary principle and intergenerational equity have met a similar fate. These have been replaced by the road-tested tools of short-term political expediency. We have looped back to closed doors, ministerial meddling, corporate influence and invitation-only access.

My hope is that Islanders will not be discouraged by this and will continue to find ways to have their voices heard. We are running out of runway.