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.