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.

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. . (https://www.nationalobserver.com/podcast/race-against-climate-change/how-we-eat).. (   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. “.https://e360.yale.edu/features/how-the-loss-of-soil-is-sacrificing-americas-naturalheritage?fbclid=IwAR0cNqt0DXgP1Cq7xxtHtGyP4wMgQ3frnwVrDkoTt3E_wLWNJXIogp-5DJI.

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.

Ending the moratorium: Credible science and comprehensive data or empty rhetoric and baseless reassurances?

Don Mazer and Boyd Allen

Part l.

The Water Act Process: From exemplary public consultation to industry led policy

It took 7 years, but now Prince Edward Island finally proclaimed a Water Act. There are certainly reasons to celebrate this. The Act contains guiding values that recognize water as a common good and a public trust. There is acknowledgment of the precautionary principle and the need to preserve water for future generations.   Yet, how much the Act will help to remedy the poor track record of the Government and its departments in protecting PEI’s waters remains to be seen.

The impetus for the development of the Water Act began at Legislative Standing Committee meetings in 2014. The potato processing industry was pressuring government to lift the moratorium on high capacity wells for agriculture, and many citizens and groups opposed this.

It is important to appreciate that the development of the Water Act reflected an exemplary process of public consultation, because it stands in such sharp contrast to the current approach of Minister Myers and the King government. This Water Act consultation period was a time when there was meaningful collaboration between government and citizens, when all Islanders had a chance to express their ideas, and when there were many opportunities for public input. Government was receptive to requests for transparent processes, and was flexible in meeting the needs of the public.  Citizens and groups responded with enthusiasm and interest and a strong commitment to this process. The result was a series of excellent, thoughtful and well researched presentations by groups and individuals at public meetings across PEI. Government seemed to actually welcome and value public input into the development of policy.  The Environmental Advisory Council report was an accurate reflection of these presentations, and included the strong opposition from a large majority of presenters to ending the moratorium on High Capacity wells for agriculture.

After being reviewed and debated clause by clause, The Water Act was passed by the provincial legislature in December, 2017.  It was the ground breaking product of participatory democracy and a step toward consensus based governance.

But since that time, we have had a change in government and four Environment Ministers, each reflecting the biases current in their Caucus and the Premier’s Office. The Water Act process has been transformed through each of these changes and has fallen on and off the priority list. The robust process of public consultation on the Act was replaced by a consultant driven “dot democracy” method for the regulations, with limited opportunities for people to directly express their ideas. The current minister is unresponsive to requests for meetings.

Trust has eroded in Government’s ability to protect our water, to listen to and collaborate with citizens and to resist corporate influence.  Anoxic conditions, high nitrate levels and fishkills continue to seriously impact P.E.I.’s waterways. Kilometres of Winter River stream beds continue to go dry each summer. The Government even violated its own regulations to permit a group of potato producers to extract water from the Dunk River in 2020 though the flow levels were below legal limits. In lieu of transparency, Government made this possible through closed door meetings and subsequent ministerial orders.

We have moved from a textbook template of public engagement and consensus based governance to a government led by industry, doing whatever if feels appropriate to achieve its short term goals. Virtually all lines of communication have been ignored. Portals for public engagement have been effectively blocked. The multiparty Standing Committee that Dennis King celebrated as a model of collaboration and transparency, is now presented by his Minister as a target of derision, their recommendations easily disregarded. Minister Myers’ unfettered boosterism of the potato processing industry appears to be government policy and has not been discouraged by his leader or his party. 
 

Part II.  A Water Conservation Strategy or an Irrigation Strategy?

As recognized by all parties in the Water Act process, Minister Steven Myers, and the King government have repeatedly emphasized that decisions about water use will always be based on careful scientific considerations, sound data and sustaining the water source for future generations. However, the decision to end the moratorium on high capacity wells for agriculture at this point reflects none of these values.  Communications from government about this decision offer us empty rhetoric and baseless reassurances, telling us how nonexistent policies and plans will protect our water.

We now hear little about the comprehensive four year study proposed by UPEI’s Dr. Michael van den Heuvel intended to provide specific data about the impact of high capacity  wells on watersheds. While there were concerns raised by environmental groups on the lack of details of this study, it was heavily promoted by industry groups and government as a prerequisite to lifting the moratorium. In Minister Myers’ latest announcement, there is no mention made of this study or anything to replace it for that matter.  Minister Myers assures us that we have had all the information that we needed for 19 years to end this “silly moratorium”. The implication is that no new data is needed to fundamentally change these water extraction regulations. Perhaps the four year delay and the inability to control the resulting conclusions limited their enthusiasm.

Communications from government about this decision offer us reassurances that the protection of our water is the root of these changes. Unfortunately this is based on an undeveloped irrigation strategy and an undetermined drought contingency plans.  These two ideas are vital to preventing unsustainable water extraction. Shouldn’t they be in place before all the applications for new HC wells start flowing in?  Shouldn’t there be public consultation about their development?

Government chose to lift the moratorium in response to the claim that it discriminated against agriculture.  But why continue to single out agriculture? Government should use this opportunity to develop a broader water conservation strategy, that places irrigation for farming in the context of all the needs for water that other industries and interests, citizens and ecosystems have.

It is encouraging to hear support at a recent Standing Committee meeting for developing systems of water governance that include a diverse range of interests and stakeholders. The Coalition for the Protection of PEI Water proposed such models of Community Based Water Governance in two submissions to the Environmental Advisory Committee during the Water Act process, and look forward to contributing to this discussion.

Government asks us to trust their good intentions, to trust their ability to monitor the well being of all waterways, to trust the expertise in their department. They ask Islanders to accept their reassurance without providing supporting data or any practical template of what is required to administer these changes in regulations or monitor their impact. They expect us to accept their continuous message that there is plentiful and abundant groundwater. They ask for all this public trust in the context of the many instances where water and wildlife health have been jeopardized under their watch.

Despite this, Minister Myers continues to reassure us that there will be meaningful public consultation. There is just no indication of what form this will take. Given his contemptuous response to any earlier recommendations from the Standing Committee which he disagreed with, how impactful this consultation will be is certainly in doubt.

The decision to end the moratorium seems to have been the government’s preferred outcome all along. 

Don Mazer and Boyd Allen are on the board of the Citizens’ Alliance of PEI, a member organization of the Coalition for the Protection of PEI Water

PEI’s Water Act, What’s Missing?

The fact that the Water Act will finally come into effect this week should be a source of celebration in Prince Edward Island. The Act contains many positive features, and in many ways reflects the values expressed by the Islanders who have over the past seven years, taken time to participate in public consultations and comment on the Act and its accompanying regulations.

But Minister Myer’s announcement on June 10 has dampened enthusiasm for the long-awaited legislation. Once again, the Minister has indicated just how easily this government responds to the powerful voices of industry and how little they hear or care about the voices of concerned Islanders who have consistently said “no” to lifting the moratorium on high-capacity wells for agricultural irrigation. Public support for maintaining the moratorium is based on the need to protect this Island’s groundwater, for our health and the health of future generations. And because Prince Edward Island’s ecosystems, already under threat in so many ways, depend on preservation of groundwater.

As the Coalition wrote in an April opinion piece in the Guardian, “trust in government’s ability to protect our water, to resist corporate influence and to listen to citizens has eroded particularly in the 3 ½ years since the Water Act was passed. Fishkills, anoxic conditions, and high nitrate levels continue in our waters.  Last summer, the government violated its own regulations by permitting five farmers to extract water from the Dunk River, when water levels were dangerously low.”

We are particularly disappointed that the moratorium is going to be lifted on the basis that licensing of high-capacity wells will be done according to rules that are as yet, non-existent. 

The idea that high-capacity wells will be permitted, provided they are constructed in accordance with an irrigation strategy may sound good, until one realizes that actually, there is no irrigation strategy.

Will all water users be at the table to determine an acceptable strategy? After all, we all have a stake in determining how water is allocated in this province for both consumptive and non-consumptive uses. And even if that strategy is to emerge and is compatible with the new Act and its regulations, the wells will not be subject to metering nor the strict limitations on water usage recommended by the PEI Legislature’s Standing Committee on Natural Resources and Environmental Sustainability, leaving us all to wonder about the pledge by this Government to the protection of Prince Edward Island waters and the gathering of scientific data to assess the effects of high-capacity wells.

The Act will also require farmers seeking well permits to submit a drought contingency plan, or a plan to reduce water use during extreme drought conditions, to the province. But there’s been no discussion of what should be included in such a plan.

This is a classic example of putting the cart before the horse and in this case the cart itself seems to be missing a competent driver.

Ann Wheatley and Marie-Ann Bowden for the Coalition for the Protection of PEI Water

Published in the Charlottetown Guardian, June 17, 2021

Water Act Debated in Legislature

The Water Act was tabled for second reading in the P.E.I. Legislature on November 29. As debate continues, and in the absence of further public consultation, it is important for MLAs to hear from us. The Coalition has identified several ways in which the act could be improved:

  1. Enshrine that water is a right.
  2. Make the fracking ban a real ban
  3. Use the right names for the terms: precautionary principle, intergenerational equity
  4. Do not allow municipalities to to exceed limits on water withdrawals
  5. Put the moratorium on high capacity wells in the Act
  6. Recognize Indigenous title and jurisdiction to watersheds in the Water Act. 

Continue reading “Water Act Debated in Legislature”

Winter River/Tracadie Bay Watershed Group on the Draft Water Act

UntitledSarah Wheatley and Cathy Corrigan of the Winter River/Tracadie Bay Watershed Group made some excellent points in their presentation, including the need to address the issue of moving water from one watershed to another:

“Banning water exports from PEI is a good step, but it doesn’t address an existing problem.

Water is being exported from the Winter River watershed in the process of supplying Charlottetown with water.

Other provinces have banned the movement of water between watersheds (ex. BC, ON).

Small scale exports, across small distances might not cause much issue, but the levels exported from Winter River clearly do have a negative impact.”

See their powerpoint presentation here

Draft Water Act Released

The long-awaited first draft of a Water Act for PEI has been released! And now the second round of consultations begins. To help us prepare for the consultations, the Coalition for Protection of PEI Water will hold a MEETING on Monday, March 20 at 7 pm at the Farm Centre in Charlottetown. Everyone is welcome to come and share their first thoughts about the proposed legislation.

DSCF2668Schedule of public meetings

  • Thursday, March 30, 7:00 to 9:00 pm – Kaylee Hall, Pooles Corner
  • Monday, April 3, 7:00 to 9:00 pm – Westisle Composite High School, Elmsdale
  • Wednesday, April 5, 7:00 to 9:00 pm – Credit Union Place, Summerside
  • Monday, April 10, 7:00 to 9:00 pm – Murphy’s Community Centre, Charlottetown

If you would like to make a presentation at one of these meetings, please pre-register with the Department of Communities, Land and Environment, by e-mail sjmoore@gov.pe.ca(link sends e-mail) or by phone (902) 368-5028.

Please note that each presentation will be limited to ten minutes.

Water Act White Paper

Environment Minister Robert Mitchell tabled the much awaited white paper on the proposed water act.
It is time to get informed and get involved.  A group from the Coaltion for the Protection of PEI Water is working on a letter for the papers to assist Islanders in learning about the process and encourage government to work with Islanders to develop a comprehensive, sustainable act.

Here is a brief description of the timeline:
  • Fall 2015: public consultations on the white paper and what should be in the Water Act carried out in several communities.  A panel made up of some members of the Environmental Advisory Council will be at every meeting, and the meetings will be moderated by the highly respected Jean-Paul Arsenault, who used to work for government and helped with a lot of those previous Reports and Roundtables (which are linked in the white paper).
  • Winter/Spring:  Department of Communities, Land and Environment works on draft Legislation
  • Spring 2016: second series of public consultations on draft water act
  • Fall 2016 (November): Water Act legislation tabled in the P.E.I. Legislature.

This is a very short timeline, and may be too ambitious. BC spent 6 years on their act and are still working on the legislation.
Public engagement and input need to be truly incorporated into the document.

The Department of Communities, Land and Environment website on a water act:
http://www.gov.pe.ca/wateract/

The link to the actual white paper:
http://www.gov.pe.ca/photos/original/wateract.pdf