Submission on Canada’s 2030 Biodiversity Strategy

Mr. Martin Lajoie
Director, National Biodiversity, Canadian Wildlife Service
Environment and Climate Change Canada

Re: Toward a 2030 Biodiversity Strategy for Canada: Halting and reversing nature loss

Dear Mr. Lajoie,

Pulse Canada has been actively engaged in Canada’s biodiversity commitments. We were present at the 15th Conference of Parties (COP15) to the United Nations Convention on Biological Diversity in Montreal and hosted an event within the Canadian Pavillion to bring the voice of Canadian grain farmers to the conference and show how they lead the sustainable management of agriculture. We are pleased to further this engagement with comment on the discussion document and help shapes Canada’s 2030 National Biodiversity Strategy.

Pulse Canada is the national association representing growers, traders and processors of Canadian pulses (dry peas, lentils, dry beans, faba beans and chickpeas). Our mission is to lead a profitable and sustainable Canadian pulse industry through innovation, efficiencies, and increased value. Canadian pulse growers are a fundamental component of sustainable agriculture systems in Canada, as the nitrogen fixation capacity of pulses provides a key environmental benefit to Canadian cropping systems. Adding pulses 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 2021 reduced greenhouse gas emissions from Canadian agriculture by approximately 3.6 million tonnes (CO2 eq).

As a result, Canadian pulse farmers produce some of the most sustainable crops in the world. This includes the adoption of beneficial management practices that have a positive impact on biodiversity, such as no-till cropping systems, vegetative filter strips and buffer strips, shelterbelts, wetland retention and grassland preservation. Consideration of the biodiversity found within the field crop itself should not be overlooked, including the diverse soil microbial community that supports a healthy soil and resilient cropping system.

Canada’s regulatory landscape is designed to mitigate the risks of fertilizer and pesticide applications on biodiversity. In addition, modern technologies applied on farms help to further reduce pollution risks. Pulse Canada firmly believes that if further mitigation of risk is required it can be achieved through further adoption of new technologies on farm, such as sectional control, variable rate application and sprayer technology rather than any arbitrary reduction in the use of fertilizer or pesticides.

To properly understand and report on Canada’s progress towards meeting the targets within the Global Biodiversity Framework, there is an immediate need for better baseline data to measure and mange biodiversity performance in Canada. Without quality data, there is a high risk of implementing tactics that do not provide the desired outcome while also limiting the productivity of the agriculture sector.

Finally, food security and agriculture productivity must be considered during the development of the biodiversity plan. Canadians and customers around the world rely on our agriculture system to deliver food and other agriculture products. Reconciling economic tradeoffs, food security, and the long-term need for restoring ecosystem functioning in agricultural areas is a complex challenge that requires careful consideration in assessing the feasibility and cost of implementation. To that end we recommend a commitment to the following:

1. Farmer involvement - Any proposed biodiversity strategy and action plans affecting Canadian agriculture need to substantively engage agricultural groups and agriculture producers throughout policy development, communication, and implementation.
2. Using data and expertise to find solutions – Agriculture and Agri-Food Canada (AAFC) must play a strong leadership role within government to ensure the agriculture sector’s hands-on expertise in managing productive landscapes informs this process and supports pragmatic solutions that reflect the realities of modern agricultural systems.
3. Agriculture Economic Impact Assessments - ECCC must work closely with AAFC in adopting a cross-cutting lens on agricultural issues within their purview, assessing any potential effects on agricultural sustainability, regional economies, national and global food security to inform this approach.

Thank you for the opportunity to share the ideas and concerns of Canada’s pulse industry. Please find detailed responses to the discussion document questions in the Annex below. Canadian pulse growers, processors and exporters have a positive impact on the economy and the environment. We remain committed to working with the government to ensure our industry remains competitive while meeting Canada’s biodiversity commitments as outlined in the Global Biodiversity Framework. We look forward to continuing to contribute to the formation of this strategy.

Please do not hesitate to contact us if you require additional information.

Sincerely,

Greg Cherewyk
President
Pulse Canada

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Pulse Canada response to overarching questions.

What are the key features of a successful 2030 Biodiversity Strategy?

• The Canadian Pulse industry is committed to engaging with government in the development of a strategy that improves biodiversity without jeopardizing farmers’ productive capacity.
• Goals and targets in the 2030 Biodiversity Strategy must be outcome-based, achievable and be based on science.
• Robust science and data are critical to translate international targets to the farm level and to ensure farmers have the tools needed to respond to the complex challenges facing our climate and food systems.
• A biodiversity strategy must also recognize the current and future realities of food insecurity, disruptive geopolitics, and a changing climate.
• Any targets in Canada’s strategy must be based on scientific evidence and data to accurately identify threats to biodiversity while avoiding unintended consequences.
• A strategy must also consider that Canadian farmers continue to increase their productivity, producing more food with fewer inputs on the same available land, thereby reducing the pressure on land use and change.
• Increasing productivity in Canada also reduces pressures to clear more land for food production around the world, which is of particular importance for ecosystems of high ecological diversity globally.
• A robust biodiversity strategy must also consider land fragmentation including urban sprawl, solar farms, and other land use changes.
• A biodiversity strategy must also include urban municipalities who can play a major role in providing pollinator habitat, increase diversity in tree species, and contribute to bird and other species biodiversity.

What are the most significant challenges and opportunities to achieving the Kunming-Montreal Global Biodiversity Framework targets in Canada? What successful initiatives could we build upon?

• The numerical targets associated with reduction in pollution risk of excess nutrients and pesticides by 50% are arbitrary and lack robust evidence and reasoning for being chosen. With little understanding of what risks need to be addressed with the use of these tools in Canada to protect biodiversity, the unintended consequences are high. It is our expectation the implementation plan remains in scope of the language of the target (reduction of risk) and does not result in the removal of the crop protection products currently allowing Canadian farmers to maintain and increase their sustainability.
• While the global biodiversity framework provides an opportunity to strengthen the fundamental role biodiversity plays globally, there are significant risks to arbitrary targets that creep in scope to use reduction or prescriptive language without a complete understanding of the underlying agricultural systems.
• Any targets and goals must focus on outcomes, not practices. Targets must be achievable, based on science, and address important data gaps before implementation is considered.
• The data to inform baseline number of species currently does not exist. Any outcome-based targets must have complete and robust datasets to assess changes over time. The government must increase investment into monitoring biodiversity to better understand the current reality of diversity and number of species and to be able to measure increases over time.
• Outcome-based targets provide the flexibility for adoption of practices that best reflect individual circumstances, farm and business sizes, production systems and practices.
• Prescriptive targets developed through international consensus can also fail to recognize where countries like Canada have already taken bold steps to advancing sustainable agriculture and adopting innovative practices.

Are there targets where Canada is already making good progress and others where Canada should focus more attention?

• Biodiversity is a significant pillar of farming. Canadian farmers depend on the natural ecology and its biodiversity for their livelihoods. Farmers employ various practices to safeguard and improve biodiversity at the farm and field level including Vegetative Filter Strips, border strips, shelterbelts, undisturbed vegetation, woodlots and wetlands.
• Farmers employ various biodiversity practices through regular crop rotations, cover crops, buffer strips, and wetland/grassland management to maintain wildlife habitat and diverse species across Canadian farmland.
• Canadian agriculture is among, if not the most sustainable on a global scale and continuously improving. The rapid adoption of technology and innovation has resulted in vast improvements in soil health, carbon sequestration and reductions in emissions from field operations due to no-till/zero-till.
• The adoption of no-till has also increased the survival of fowl and migratory birds and a steady increase in numbers with improved and undisturbed nesting sites.
• Farmers employ innovative spray technologies such as pulse width modulation (PWM) which allows individual nozzles to be activated, reducing overlap and allowing for green on brown activation, reducing overall pesticide use from 50%-90%. PWM and innovative software has also led to green on green spray technology, facilitating sprayers to target green weeds in a green crop. Governments could aid in the accelerated adoption of these technologies as cost remains a barrier to adoption.
• Agriculture depends on healthy agro-ecosystems, yet environmental policy often does not seem to consider agriculture. Government policies, such as fertilizer emission reductions, fail to recognize the sectors’ progress to date while potentially increasing global food insecurity.
• Arbitrary numerical targets may limit farmers’ use of tools that are facilitating agriculture’s ability to respond to the challenges that food systems face. A full suite of tools and various production practices is required to sustainably intensify food production, advance biodiversity conservation, and address climate change.

What measures should be prioritized and implemented as soon as possible to ensure we meet the 2030 targets and are on track to reach the longer-term 2050 goals?

• A 2030 Biodiversity Strategy should acknowledge that there’s no single approach to supporting biodiversity in agriculture, and instead empower farmers to employ a diverse number of practices best suited to their individual farms. This includes sustainable intensification.
• There are many synergies in advancing both biodiverse ecosystems and Canada’s agricultural production capacity through improved soil health, carbon sequestration and other agricultural nature-based solutions. This in turn leads to increased resilience in the face of the ever-increasing extreme weather events.
• Farmers are already undertaking a wide range of practices that are aligned with biodiversity objectives. Farmers are committed to the responsible use of crop nutrients and pesticides through stewardship and beneficial management practices. Field level stewardship protects against adverse impacts on biodiversity and ecosystem health. Targets related to practices are simplistic and often fail to recognize the many diverse agricultural practices that exist, and the full benefits of innovation across the agriculture sector.
• Widespread adoption of no-till and conservation tillage practices promote carbon sequestration and maintain soil biodiversity.
• Pollinator extension and education as well as innovative crop protection products has allowed the mutually beneficial relationship between crops and pollinators (including bees) to flourish.
• On-farm biosafety practices on Canadian farms aim to prevent the introduction of plant pests and invasive species and strong Species at Risk legislation guards against species extinction.
• A large and growing proportion of farmers also practice elements of integrated pest management (IPM), which is defined by the FAO as “the careful consideration of all available pest control techniques and subsequent integration of appropriate measures that discourage the development of pest populations”.
• IPM practiced on Canadian farms “combines biological, chemical, physical and crop specific (cultural) management strategies and practices to grow healthy crops and minimize the use of pesticides, reducing or minimizing risks posed by pesticides to human health and the environment for sustainable pest management.”
• Farmers employ various best management practices to ensure efficient use of fertilizers and to minimize loss. Examples include the 4R Nutrient Stewardship to improve fertilizer efficiency, precision agriculture, and variable rate technology to reduce fertilizer emissions and eutrophication of wetlands, lakes and streams.

No target is an island: What overarching tools and solutions are critical for making progress across multiple targets?

• A 2030 Biodiversity Strategy must be continuously evolving, have a strong and consistent agricultural voice, informing the development and implementation of plans and be in conjunction with other policies on ecosystem services and nature-based solutions.
• An enabling mechanism would be to consider agriculture more broadly in government policy. At times, environmental and agriculture policies seem to be at odds; however, they could and should be complementary and find synergies to benefit the environment without impeding agricultural productivity.
• It is critical to have constant interaction with agriculture stakeholders to understand and monitor the practices that influence biodiversity.
• A successful 2030 Biodiversity Strategy is also one that consults broadly with the agriculture sector and across different Government departments and agencies to ensure policy coherence and reduce any duplicative efforts.

What additional knowledge and enabling mechanisms (e.g., networks, policies) are critical to inform implementation decision-making at all levels?

• Among the most significant challenges to achieving improved biodiversity outcomes is current knowledge and data gaps. Provincial programs for monitoring biodiversity are not equal and the current baseline measurements are incomplete and underfunded.
• Addressing these gaps will help improve our knowledge of the connections between modern agriculture and biodiversity, supporting targeted initiatives or building upon successful ones. Given the need for more data, it is hard to assess how well Canada is doing in any particular target.
• While some progress has been shown through the Government of Canada AAFC’s Agri-environmental indicators (AEIs), through the CABIN (Canadian Aquatic Biomonitoring Network) protocol, and other provincial efforts (such as the Alberta Biodiversity Monitoring Institute in Alberta), there are challenges in the effectiveness in measuring key environmental conditions, risks, and changes resulting from agriculture practices.
• The current limitations in establishing direct cause and effect also limit the meaningful actions based on causality rather than on correlations or assumptions, and unfortunately lead to the misrepresentation of modern agriculture as being counter to biodiversity conservation.
• Baseline measurements to assess current levels of biodiversity are still lacking across many animals, amphibians, insects, and aquatic invertebrates. Invertebrate species and amphibians are two examples where more public investment needs to be made to establish baselines to measure improvements.

In drafting the 2030 Biodiversity Strategy, what individuals’, communities’, or organizations’ perspectives, knowledge, and skills should be meaningfully amplified to make progress on reducing threats to biodiversity?

• The development of a strategy has the potential to improve engagement with non-agriculture stakeholders on modern agriculture’s capacity as a provider of nature-based solutions while countering prescriptive practices based on ideology.
• The creation of a strategy provides the opportunity to advance sustainable agriculture and strengthen the link with biodiversity, however, certain targets could have a detrimental impact on the Canadian Pulse sectors’ contributions to domestic and global sustainability goals.

What are the key human needs and values to be addressed to make biodiversity loss a mainstream concern? What does success look like?

• A biodiversity strategy should ensure that all members of the grain value chain are part of the conversation as there are many leading experts in the development and adoption of technologies which have proven to bring benefits for the environment.
• Success should be a win-win for the environment, agriculture, and society, where progress is made without compromising food production and other human needs.
• A clear example of this is the Canadian success story of adopting no-till or zero-till practices. It is well-documented that no-till farming practices in Canada sequester several megatonnes of CO2 equivalents per year. This technology-based environmental accomplishment requires the use of nonselective herbicides to control weeds in place of tillage, an often-overlooked practice which has been viewed as negative by certain eNGOs and members of society.
• If pesticide risk reduction targets were to ban or curtail the use of herbicides, sequestered carbon from the millions of acres under zero-till could be released at scale. Reverting to tillage for weed control would discontinue each year's additional carbon sequestered, as well as releasing carbon sequestered over zero-till's 25+ year success story.
• Advancements in nitrogen use efficiency through ESN (Environmentally Smart Nitrogen), nitrogenase inhibitors and other nitrogen coatings have resulted in slow release of nitrogen fertilizers, reducing nitrification, de-nitrification and leaching.
• Other technological advancements in crop protection product applications include green on brown spray technology, pulse width modulation and other pesticide reduction innovations. Wider adoption could be facilitated through Canadian Sustainable Agricultural Partnership programming.
• No-till adoption has also resulted in improved soil health and lower GHGs emissions from tillage. Stories such as this should be amplified to showcase the benefits of how technology, biodiversity and agriculture can co-exist and complement each other.