To whom it may concern,
Pulse Canada has been actively engaged in the proposed fertilizer emissions reduction target (FERT) since it was announced in December 2020, and we are pleased to comment on the discussion document which was released on March 11, 2022.
Pulse Canada is the national industry association that represents growers, processors and traders of pulse crops (peas, lentils, dry beans, chickpeas and faba beans) in Canada. The Canadian pulse industry has been steadily growing for decades, with Canada now being the 2nd largest producer and largest exporter of pulses in the world. Pulse growers have always been at the forefront of reducing emissions, as growing legume crops like pulses and soybean reduces the nitrogen requirements of the crop rotation, due to the nitrogen fixation capacity of legumes. Adding pulses and soybeans to crop rotations is a proven method to immediately reduce greenhouse gas emissions from Canadian cropping systems while being agronomically beneficial without the need to test and adopt new technologies. In fact, the 3.5 million hectares of pulse crops grown in 2020 reduced greenhouse gas emissions from Canadian agriculture by approximately 3.6 million tonnes (CO2 eq). This reduction in greenhouse gas emissions represents 90% of the 4 million tonne (CO2 eq) emission reduction target of the FERT.
The Importance of Nitrogen for Sustainable Food Production
There is no doubt that nitrogen fertilizer is essential as a source of crop nutrients, specifically in the context of a sustainable production system that is responsible for feeding the world. Nitrogen is the nutrient that is the most limiting to crop productivity, and its use directly increases yield and therefore profitability. The need to maintain productivity is particularly topical today given the need to maintain global food security and in-turn, global political stability. In addition, biofuel policies being adopted in Canada and the USA are conditional on the availability of high-yielding crops as feedstock, and those yields will largely be dependent on nitrogen fertilizer. Nitrogen fertilizer’s influence on crop yield also reduces the amount of land needed to produce food, decreasing land conversion pressure on natural areas like grasslands, wetlands and forests. At the same time, nitrogen fertilizer is an expensive crop input for growers, and these costs have increased recently with the increased cost of natural gas and global supply chain disruptions. With cost alone, growers have ample incentive to maximize the efficiency of nitrogen fertilizer and Canadian growers invest in technologies and practices which improve nitrogen fertilizer use efficiency.
Canadian Growers Focus on Innovation
Canadian growers have a strong record of practices targeted at improving fertilizer use efficiency and improving productivity. Growers across Canada have embraced the principles of 4R Nutrient Management, with advances made in the adoption of a broad suite of practices. Soil sampling and establishing fertilizer application rates based on realistic and economic crop yields have become common-place. In Western Canada, there has been a steady shift away from broadcasting nitrogen fertilizer, to banding fertilizer at the time of seeding. Variable rate application, split-application and enhanced-efficiency fertilizers are all practices that Canadian growers increasingly employ on farm to improve the efficiency of their fertilizer usage. However, there is a need to maintain the momentum of growers’ adoption of innovative practices, of which many require significant investment and research to ensure they are practical, economic and effective in terms of emission reductions.
Crop rotation is sometimes considered an equally important 5th R, with the incorporation of pulses and soybeans representing an excellent example of how rotating crops can reduce fertilizer emissions from a cropping system. Canadian growers have greatly expanded the use of pulses in rotation in the past two decades, with pulse production growing from 6% of all Canadian field crops in 2011 to 10% in 2020. Decades of research have shown that nitrogen fixing legumes in Canadian cropping systems reduce the requirement for nitrogen fertilizer in the crop rotation, and that this benefit substantially reduces greenhouse gas emissions as well.
Developing an Emissions Reduction plan that Works for Growers
The FERT has elicited a strong response from the Canadian agricultural community for good reasons. Growers have been focused on fertilizer use efficiency and productivity for decades, and a target with an established benchmark of 2020 will disregard decades of previous innovation and improvements. The government’s target was set in advance of consultation with industry, and specifically, without consultation from those most directly impacted. It was also set without clarity on how the target could be measured, and without a common understanding of impacts on productivity and the economic impact for the industry.
Pulse Canada is willing to play a constructive role in partnership with the government to establish practical and implementable solutions on how to reduce emissions related to fertilizer while ensuring Canadian growers can continue to make the decisions that best suit their individual businesses.
Our recommendations include:
1. AAFC must continue to make clear that there will be no policy measures put in place to limit the use of nitrogen fertilizer in Canadian agriculture.
There has been much discussion among growers and in the media regarding whether the FERT is a first step to limiting the use of nitrogen fertilizer in Canadian agriculture. Nitrogen is critical to achieving Canada’s production and economic growth targets for the agricultural sector. Given valid concerns with the approach outlined in the EU’s Farm to Fork policy regarding fertilizer and pesticide use, AAFC must continue to reiterate that the government will not be restricting fertilizer use for Canadian growers and restate Canada’s commitment to modern, science-based agricultural decision-making.
2. Industry and government need to work together on an action plan
It is imperative to increase meaningful consultation with the agriculture industry on this topic, as this industry will be most impacted and are incentivized to find solutions. The development of an industry/government task force is required to develop an action plan for the FERT and other areas where emission reductions are possible in the agriculture landscape. Importantly, consideration needs to be given to a wider scope of measures and practices that can be adopted to reduce emissions. On the farm, this can include practices such as drainage improvements that decrease emissions from saturated soils, and the conversion of unproductive lands to natural areas. Off the farm, new fertilizer manufacturing technologies are needed to decrease upstream emissions from nitrogen fertilizers. A task force will be responsible for developing feasible and implementable targets and timelines for emission reductions, identify the necessary incentives and programs that will achieve the targets, the data collection system, a proposed methodology for target setting and monitoring, and an implementation plan.
3. Leveraging the carbon benefit of the Canadian pulse industry
The Canadian pulse industry already produces a major benefit by reducing greenhouse gas emissions from Canadian cropping systems. This benefit can be leveraged in crop rotations, but also in feed and food applications, which both represent market growth opportunities for the Canadian pulse sector. Recent findings reveal that pulses incorporated into 6-year crop rotations across several provinces, reduce greenhouse gas emissions by up to 21%. Peas incorporated into Western Canadian swine diets have been shown to reduce the carbon footprint of Canadian pork by 18%. And pasta reformulated with 30% lentil flour has a carbon footprint that is 30% lower. The responsible growth of the Canadian pulse industry will further decrease greenhouse gas emissions, specifically from fertilizer. A scenario for the pulse industry of 40% growth by 2030 would further decrease greenhouse gas emissions by 1.4 million tonnes (CO2 eq). This reduction in emissions is significant compared to the recent commitment during the FPT meeting to reduce emissions from the Canadian agricultural sector by 3 to 5 million tonnes (CO2 eq). The Canadian pulse industry has identified several key areas where the government can invest to ensure that the Canadian pulse industry can continue to grow in a sustainable fashion. Pulse Canada and its members would be pleased to speak with representatives from AAFC and ECCC regarding the opportunity that the Canadian pulse industry represents regarding the FERT as well as greenhouse gas emissions from Canadian agriculture systems as a whole.
4. Improved data which is reflective of actual practices on Canadian farms
The approach to data that is utilized for the National Inventory Report (NIR) is not sufficient for the FERT. The NIR methodology relies solely on bulk provincial sales of fertilizer, which is then attributed to regions and crops utilizing assumptions. The method does not account at all for 4R practices such as placement, timing, and source. Pulse Canada proposes that AAFC work with industry to develop a data collection program specific to the needs of the FERT, incorporating real farm data from the benchmark year of 2020, continuing until 2030. This data collection program would capture relevant 4R data specific to each crop, in each production region of Canada.
5. Improved methodology reflecting 4R practices and their impacts
Currently, Canada’s modelling for nitrous oxide emissions does not account for differences from many 4R fertilizer management practices. Pulse Canada understands that the modelling team at AAFC and ECCC responsible for Canada’s soil nitrous oxide emissions modelling is currently considering how to incorporate practices such as banding, timing, and enhanced efficiency fertilizer into Canada’s modelling, based on current available research. This effort should be prioritized and accelerated in order to account for the beneficial management practices adopted to date by Canadian growers, and those practices that will be adopted in the future. In addition, Pulse Canada is aware of the new method for Canadian soil N2O emission quantification developed and published by AAFC and ECCC scientists (Liang et al., 2020). This method provides a more accurate estimate of soil N2O emissions in Canada, which is more reflective of soil, topographical and climate impact, and differentiates N2O emissions from synthetic nitrogen, manure and crop residues. The utilization of this new method should be prioritized and accelerated for the NIR as well as the FERT, in order to more accurately measure current and future emissions of greenhouse gas emissions from Canadian agriculture.
Thank-you for the opportunity to share the concerns and ideas of Canada’s pulse industry.
Canadian pulse growers, processors and exporters are important contributors to the Canadian economy. We are committed to working with you to ensure our industry remains competitive while lowering our carbon footprint. We look forward to being consulted further as this process unfolds.
Please do not hesitate to contact us if you require additional information.
Pulse Canada is the national association of growers, traders and processors of Canadian pulses, also known as lentils, dry peas, beans and chickpeas. Pulses are an essential part of a healthy and sustainable diet. Pulses and pulse ingredients can help food manufacturers improve the nutritional and functional quality of food products.