Manitoba Clean Environment Commission 305-155 Carlton Street Winnipeg, Manitoba R3C 3H8 Fax: 204-945-0090 Telephone: 204-945-0594 www.cecmanitoba.ca

305 – 155 Carlton Street Winnipeg, MB R3C 3H8

Ph: 204-945-7091 Toll Free: 1-800-597-3556 December 18, 2007 Fax: 204-945-0090 www.cecmanitoba.ca

Honourable Stan Struthers Minister of Conservation Room 330 Legislative Building 450 Broadway Winnipeg, Manitoba R3C 0V8

Dear Minister Struthers:

Re: Hog Production Industry Review

The Panel is pleased to submit the Clean Environment Commission’s report on the review of the environmental sustainability of the hog production industry in Manitoba.

Sincerely,

Terry Sargeant, Chair

Wayne Motheral

Edwin Yee Manitoba Clean Environment Commission Contents

Foreword ...... v Executive summary ...... ix Résumé ...... xiii 1 Introduction ...... 1 1.1 Mandate and terms of reference...... 1 1.2 The investigation...... 2 1.3 The Report...... 2 2 Environmental sustainability and the hog-production industry ...... 3 2.1 Environmental sustainability...... 3 2.2 Agriculture, livestock production, and sustainable development...... 5 2.3 Agriculture and the environment...... 7 3 Agriculture and the Manitoba economy ...... 9 3.1 Farm population trends...... 9 3.2 Structure of farms...... 10 3.3 Farms and farm investment...... 10 3.4 Farm income...... 10 3.5 Agriculture’s significance to provincial economy...... 13 4 Evolution of the North American hog-production industry ...... 15 4.1 The hog-production revolution in North America...... 15 4.2 The three-site model and all-in, all-out production...... 17 4.3 The impact on Canada...... 18 4.3.1 Export industry...... 18 4.3.2 Growth factors...... 19 4.4 Social conflict and environmental concerns...... 19 4.5 The expansion of the Manitoba industry...... 20 4.5.1 Hutterite colonies and Manitoba hog production...... 20 4.5.2 The Manitoba expansion...... 20 5 Current state of Manitoba hog industry ...... 25 5.1 Decline in number of hog operations...... 26 5.2 Concentration of production...... 26 5.3 Structure of the Manitoba industry...... 26 5.3.1 Hog farms with field crops...... 28 5.4 Slaughter...... 28 5.5 Export...... 32 5.6 Impact on Manitoba economy...... 33 5.6.1 Feed...... 34

i Manitoba Clean Environment Commission 5.7 Issues facing the industry...... 34 5.7.1 Feed costs...... 34 5.7.2 Labour...... 35 5.7.3 Slaughter capacity and price...... 35 5.7.4 An appreciating Canadian dollar...... 35 5.7.5 Access to export markets...... 35 6 Barriers to sustainability ...... 37 6.1 Water ...... 38 6.1.1 Water quantity...... 38 6.1.2 Water quality...... 38 6.2 Air...... 41 6.2.1 Climate change ...... 41 6.2.3 Odour...... 41 6.3 Land...... 42 6.3.1 Changes in land use...... 42 6.4 Flora and fauna...... 42 6.4.1 Biological diversity...... 42 6.4.2 Health...... 42 7 The growth of the regulation of the hog industry in Manitoba ...... 45 7.1 Environmental regulations...... 47 7.1.1 Regulation of the hog industry in the 1960s and 1970s...... 47 7.1.2 The 1990s and the expansion of the Manitoba hog industry...... 48 Box 7.1 Manure management plans...... 51 7.1.3 Regulating the hog-production industry in the 21st century...... 52 7.2 Land-use decision-making...... 57 7.2.1 The Planning Act...... 58 7.2.2 The Planning Act amendments: 2000...... 58 7.2.3 The Planning Act: 2006...... 59 7.3 The role of Manitoba Agriculture, Food and Rural Initiatives...... 61 Box 7.2 Environmental Farm Plan Program...... 62 7.3.1 The Agri-Environment Knowledge Centre ...... 62 7.3.2 Covering New Ground (The Agricultural Sustainability Initiative)...... 63 Box 7.3 Environmental goods and services...... 63 7.4 Controlling nutrients...... 64 Box 7.4 Other jurisdictions...... 67 8 Public Input ...... 71 8.1 Nutrient management...... 72 8.2 Manure management...... 73 8.3 Land-use planning and approval...... 74 8.4 Groundwater quality...... 75 8.5 Groundwater supply...... 75 8.6 Surface water quality...... 76 8.7 Soil quality...... 76 ii Environmental Sustainability and Hog Production in Manitoba 8.8 Odour...... 76 8.9 Disease transmission...... 77 8.10 Climate change...... 77 8.11 Environmental liability...... 78 8.12 Other jurisdictions ...... 78 8.13 Other issues...... 78 9 Water quality ...... 81 Introduction to Section Two...... 81 9.1 Water quality...... 82 9.1.1 Environmental risk related to field application...... 82 Box 9.1: Audit of the Department of Conservation’s Management of the Environmental Livestock Program...... 83 Box 9.2 Cost of compliance...... 90 9.1.2 Manure storage...... 101 9.1.3 Administration and enforcement of the LMMMR...... 108 9.2 Water use ...... 113 9.2.1 Water allocation to hog producers...... 114 9.2.2 Water consumption...... 115 10 Air quality ...... 119 10.1 Climate Change...... 119 10.2 Odour...... 121 10.2.1 Manitoba regulations ...... 122 10.2.2 Mitigation strategies...... 125 10.2.3 Information gaps...... 125 11 Flora and fauna ...... 127 11.1 Biodiversity...... 127 11.1.1 Conversion of natural habitat...... 128 11.1.2 The impact of increased nutrient levels in environmentally sensitive areas...... 129 11.2 Health...... 131 11.2.1 Workplace safety and health in the hog industry...... 131 11.2.2 Animal diseases...... 133 11.2.3 Antibiotic use in hog production...... 134 12 The approval process and watershed planning ...... 137 12.1 Watershed planning...... 137 12.2 The current approval process...... 138 12.2.1 Technical Review Committees...... 139 12.2.2 The conditional-use process...... 140 12.2.3 The provincial permitting process...... 140 12.3 A new approval process...... 140 12.3.1 Site assessment...... 141 12.3.2 Reviewing the site assessment...... 141

iii Manitoba Clean Environment Commission 12.3.3 Public input into the site assessment...... 143 12.3.4 The process following the completion of a site assessment...... 143 13 Information and research ...... 145 13.1 Information...... 145 13.2 Research...... 147 13.3 Communication and information coordination...... 148 14 Conclusion ...... 151 15 Recommendations ...... 155 15 Recommandations ...... 161 References ...... 169 Appendix 1 Principles and Guidelines for Sustainable Development...... 175 Appendix 2 Guide to Public Participation...... 177 Appendix 3 Participants in the public portion of the Investigation...... 181

iv Foreword

ust over a year ago – in the fall of 2006, research necessary to ground environmental the Clean Environment Commission was regulations. Jasked to determine whether or not the In carrying out this assignment, the production of hogs, as it has developed in Commission conducted a comprehensive Manitoba, is environmentally sustainable. investigation. In a total of 20 public The simple answer is: “Yes, but ….” meetings, we heard from hundreds of The not-so-simple answer unfolds on Manitobans, who represented opinions on the pages of this report. In short, if the all sides of all of the many issues related hog production industry continues to to agricultural sustainability. We met with grow, it will not remain environmentally representatives of many organizations - sustainable unless significant resources are environmental, agricultural, and municipal, dedicated to addressing the many associated among others. And, we read extensively: environmental issues. Such resources would reports commissioned by us for this include staff to conduct the approvals investigation; written submissions provided process, to monitor compliance with the by private citizens and industry supporters; regulatory regime, and to conduct the

v Manitoba Clean Environment Commission and a wide range of literature given us by individual municipalities – is able to identify interveners. all of the hog operations in the province.) While we are of the view that our And, the government must facilitate investigation was thorough, we recognize research into a number of matters that may that our report is certainly far from the final threaten environmental sustainability. Over word on this matter. Still, we do believe the past dozen or so years, the hog industry that the recommendations we make, when has expanded more quickly than scientific implemented, will go a long way towards research. While much of this gap has been ensuring that hog production in Manitoba is closed in recent years, the capacity must environmentally sustainable. be enhanced to allow research to get out in front of any future growth in the industry. We were not asked to look at the In this regard, we recommend that a economic sustainability of hog production. Watershed Studies Institute be established to But, it is impossible not to have noted that co-ordinate and facilitate research into the the industry is currently at a proverbial many environmental issues that may impact cross-road. Although this is true of the on watersheds. We see this as being a key industry worldwide, Manitoba has its own element of the province’s water strategy, and unique elements. also one that would contribute significantly Manitoba hog producers face a number to the environmental sustainability of of challenges that were not even on the livestock production. horizon a couple of years ago. These include: We were asked by a number of parties the rapid rise in the value of the Canadian to recommend that new hog operations be dollar; the large increase in the cost of required to go through a full environmental feed, in no small part driven by the rapid assessment. We stopped short of doing expansion of ethanol production; proposed that, opting for a new process that would U. S. federal legislation, which will act as a be somewhat more stringent than the trade barrier; and the closure of a number of current Technical Review process, but not as meat-packing plants across Canada. demanding as the environmental assessment It was in this context that the Clean process. Environment Commission set out to review It is also the view of the Commission the environmental sustainability of raising that, given what we know today about the pigs in Manitoba. industry, there is no further excuse for The environmental challenges that face haphazard growth of the industry, which the industry are thoroughly canvassed in particularly marked the early years of the ensuing pages of our report. In the end, the rapid expansion seen after 1994. The we make a number of recommendations as ensuing years have seen the implementation to how these challenges can be met and of the first Livestock Manure and Mortalities managed. Management Regulation in 1998, the report It is the overriding view of the of the Livestock Stewardship Initiative, On Commission that these environmental issues Common Ground, in 2000, the report of the cannot be properly managed in a vacuum Department of Conservation’s review of the and that environmental regulation must sustainability of hog production, in 2006 be scientifically-based. To these ends, the and, now, the CEC report. The Commission government must compile a comprehensive concludes that all of these endeavours database of information in respect of provide a solid base for well-planned future hog production in the province. (We were expansion. surprised to discover that no one – the government, the Manitoba Pork Council, The Clean Environment Commission has, in the past, indicated its strong support for vi Environmental Sustainability and Hog Production in Manitoba the Province of Manitoba’s water strategy, were told about the many businesses that noting that Manitobans are in the enviable had come into being to support the industry. position of having one of the world’s best The Commission became very aware, supplies of fresh water. We have further through the investigation, that an noted that, too often, Manitobans seem to inevitable conflict arises within government take our fresh water for granted, without when it has the roles of both promoting worrying about future users. and regulating an industry. We noted, The CEC sees this investigation as a as well, that there is too often a lack of significant element of the province’s water cooperation between departments which strategy and, ultimately, its environmental play interdependent roles in the regulation strategy. While we did not focus our of the industry. This was underlined in the investigation on Lake Winnipeg, we were Auditor General’s recent report on industry always cognizant that most of the surface regulation. It is the view of the Commission water in Manitoba ultimately flows through that government would be well-advised to that lake. consider ways in which it can address such In this regard, many producers pointed matters. out that, while there have been major Many of our recommendations address strides to regulate hog farmers in recent current issues and can, and should, be years, there has been little or no progress implemented immediately. This would on the part of the City of Winnipeg to provide an immediate start to maintaining reduce its nutrient loading into the lake. environmental sustainability. Other Add to that the growth in the number of recommendations are longer term. While cottages around Manitoba lakes with what less urgent, they are equally important many perceive to be inadequate sewage in achieving long-term environmental management. This has led to a widespread sustainability. belief among hog producers that they are forced to bear an unfair burden for Acknowledgments addressing Lake Winnipeg concerns. There was a huge number of people We were cautioned that additional, involved throughout the many months of stringent regulation could threaten the our investigation, from Commission staff to economic sustainability of hog production the hundreds of Manitobans who expressed in Manitoba. This raised the question as their views or shared their experiences and to whether we subsidize the industry by expertise. weakening environmental regulation or by Above all, I would like to acknowledge other means. To this end, the Commission the contribution of those closest to the supports the stated intentions of the centre of the Investigation. They include government to provide assistance for farmers my co-panelists: during the initial, scoping in adapting to the new regulations. meetings, Norm Brandson and Wayne While we did hear from many Motheral; and in the main course of Manitobans with environmental and social meetings, Wayne Motheral and Edwin Yee. I concerns about the hog industry and its would also like to thank Commission staff evolution over the past decade and a half, members, Cathy Johnson and Joyce Mueller we also heard many positive stories. We for their skills and dedication. And a special heard that, in some communities, hog thanks to our report writer, Doug Smith, farming has created a number of jobs, which, who also undertook an amazing amount of in turn, has helped keep young families in research. All of the foregoing contributed a the communities. We heard that one town huge effort in this investigation. was even able to re-open a school. And, we We received considerable support from a number of consultants, engaged by the

vii Manitoba Clean Environment Commission Commission to help us understand the many, complex issues surrounding our work. A number of individuals also gave of their time to share their expertise and experiences in matters related to the review. We could not have carried out our investigation without the great assistance of many officials in a number of provincial government departments, including: Agriculture, Food and Rural Initiatives; Conservation; Intergovernmental Affairs; and Water Stewardship. These folks patiently explained their programs’ role in the development and regulation of the hog industry in Manitoba, as well as responding to our seemingly unending requests for information.

Terry Sargeant, Chair

December 2007

viii Executive summary

n November 2006, the Manitoba Minister and consulted with academics, federal, of Conservation made a request to provincial and municipal officials. Ithe Clean Environment Commission Based on The Sustainable Development (the Commission) that it conduct an Act, the Commission concluded that investigation into the environmental an assessment of the environmental sustainability of hog production in sustainability of the hog-production Manitoba. The Commission was tasked with industry involved determining if that assessing current environmental regulations industry can be maintained indefinitely in to determine their effectiveness for the light of its impact on air, land, water, flora, purpose of managing hog production in an and fauna. environmentally sustainable manner. The first section of this report In conducting this Investigation, the (Chapter 1-8) surveys the environmental Commission held 20 public meetings in sustainability issues associated with hog agricultural Manitoba during the winter and production, provides an overview of the spring of 2007, reviewed an extensive range evolution of the industry and current of literature, commissioned original reports, practices in Manitoba, outlines the measures

ix Manitoba Clean Environment Commission taken to regulate the industry in Manitoba, The Commission is recommending, in and summarizes the presentations made response to both climate-change and odour to the Commission by the public. The issues, that all new and expanding manure- second section (Chapter 9-13) presents the storage facilities have synthetic covers and Commission’s findings and recommendations. that operators be required to either inject The Commission recognizes that the or incorporate manure within 48 hours of regional imbalances that have developed application to fields. The Commission also between the application and removal addresses: of nutrients and the potential impact • The Farm Practices Protection Board. of these nutrients on water resources constitute the most serious environmental • The establishment of a dispersion- sustainability issues facing the industry. It theory-based farm odour guideline. is recommending that the phase-in dates for the Livestock Manure and Mortalities • Research into a range of odour-related Management Regulation phosphorus issues. (LMMMR) provisions be adjusted so that all The Commission recognizes that operators are required to be fully compliant while land (soils) and flora and fauna with the LMMMR by 2013. The Commission (biodiversity) issues do not present a also is calling for a complete ban on the current barrier to the industry’s ecological winter application of manure by 2013, a sustainability, these issues need continued review of the phosphorus provisions of the research and monitoring. It is making LMMMR within five years, and the provision recommendations in relation to the of financial assistance or incentives to following issues: livestock operators as they adjust to the • Inclusion of biodiversity conservation new regulation. In its discussion of water- considerations into the decision-making related issues in this report, the Commission process. addresses the following issues: • The shortcomings of the current science • Identification of ecologically sensitive in identifying soil phosphorus threshold sites. levels specific to Manitoba. • Workplace safety and health in hog- • The land base to which new and production facilities. expanding operators must have access. • Preparation for animal disease • The time of application of manure. outbreaks.

• The impact of application on marginal • The use of antibiotics in raising land. livestock. The current approval process needs to • The Nutrient Management Regulation. be strengthened with the ultimate goal • Pathogens and heavy metals in manure. of having decision-making take place in a watershed-management context. • The design approval, construction, and The Commission is recommending that monitoring of manure-storage facilities. this be done through the inclusion of a site assessment early in the process and • Compliance and enforcement of the broadening the range of issues that are LMMMR. considered in the approval process. Manitoba • Water supply issues. Conservation would serve as the lead agency in this new process. x Environmental Sustainability and Hog Production in Manitoba

The Commission also recognizes that there is a need for improvement in the availability of information and communication with producers and the public. It is calling on the government to improve data collection and research, as well as to establish a Watershed Studies Institute. This report is an evaluation of the environmental sustainability of the hog- production industry. The Commission is well aware of the fact that some of its recommendations will have economic impacts for producers. While much of the focus in this report is on regulation and enforcement, there is an equal, if not more important, role to be played by those who work for the government doing agriculture extension work, environmental farm planning, and in developing programs that reward farmers for providing environmental farm services. Environmental sustainability is achievable, but it cannot be put off into the future. The challenge for the government will be to develop an implementation strategy that works with producers and other members of society to ensure the industry’s social and economic sustainability. In those areas where nutrient production is currently out of balance with the environment’s ability to remove those nutrients, the province and producers must move quickly and cooperatively to bring production into balance within the next five years.

xi Manitoba Clean Environment Commission

xii Environmental Sustainability and Hog Production in Manitoba

Résumé

n novembre 2006, le ministre de la printemps 2007, elle a examiné une grande Conservation du Manitoba a demandé quantité de documents, elle a commandé Eà la Commission de protection de des rapports originaux et elle a consulté des l’environnement de mener une enquête universitaires et des représentants fédéraux, sur la durabilité de la production provinciaux et municipaux. porcine au Manitoba du point de vue de En se basant sur la Loi sur le l’environnement. La Commission a été développement durable, la Commission a chargée d’évaluer la réglementation actuelle conclu que l’évaluation de la durabilité de en matière de protection de l’environnement la production porcine du point de vue de afin de savoir si elle permet effectivement l’environnement consistait à déterminer une gestion responsable de la production si cette industrie pouvait être maintenue porcine sur le plan environnemental. indéfiniment si l’on tenait compte de ses Dans le cadre de cette enquête, répercussions sur l’air, la terre, l’eau, la flore la Commission a organisé 20 réunions et la faune. publiques dans des régions rurales La première partie de ce rapport du Manitoba pendant l’hiver et le (chapitres 1 à 8) étudie les problèmes

xiii Manitoba Clean Environment Commission environnementaux liés à la production • les conséquences d’un épandage sur des porcine, fournit une vue d’ensemble terres marginales; de l’évolution de l’industrie, décrit les pratiques actuelles au Manitoba, met en • le Règlement sur la gestion des relief les mesures prises pour réglementer nutriants; l’industrie au Manitoba et résume les • les pathogènes et les métaux lourds présentations faites à la Commission par le dans les déjections; public. La deuxième partie de ce rapport (chapitres 9 à 13) présente les résultats et • l’approbation de la conception, les recommandations de la Commission. la construction et la gestion des La Commission reconnaît que le installations de stockage des déjections déséquilibre régional qui s’est créé entre du bétail; l’application de nutriants et leur élimination, avec les conséquences potentielles que ces • le respect et la mise en application du nutriants peuvent avoir sur les ressources Règlement sur la gestion des animaux en eau, constitue le plus grave problème morts et des déjections du bétail; auquel l’industrie porcine est confrontée • des questions d’approvisionnement en d’un point de vue environnemental. Il est eau. recommandé que les dates de mise en place progressive des dispositions relatives au La Commission recommande, en réponse phosphore du Règlement sur la gestion des aux changements climatiques et aux animaux morts et des déjections du bétail problèmes d’odeur, que toutes les nouvelles soient ajustées afin que le plein respect de installations de stockage des déjections ce règlement, par tous les exploitants, soit du bétail et que toutes celles devant être atteint en 2013. La Commission préconise agrandies soient recouvertes d’une matière aussi une interdiction absolue d’épandre des synthétique et que tous les exploitants déjections en hiver d’ici 2013, une révision soient tenus d’injecter les déjections du des dispositions relatives au phosphore du bétail ou de les incorporer dans les sols Règlement sur la gestion des animaux morts dans les 48 heures après l’épandage. La et des déjections du bétail d’ici cinq ans et Commission se penche aussi sur : la mise en place d’une aide financière ou • la Commission de protection des de mesures incitatives pour les éleveurs de pratiques agricoles; bétails afin de leur permettre de s’adapter à la nouvelle réglementation. Dans le cadre • la mise en place d’une ligne directrice des questions relatives à l’eau abordées dans sur les odeurs basée sur une théorie ce rapport, la Commission se penche sur les de la dispersion des odeurs pour les points suivants : exploitations agricoles;

• les insuffisances de la science actuelle • la recherche portant sur diverses à déterminer, pour le Manitoba, les questions liées aux odeurs. niveaux limites de phosphore dans le sol; La Commission reconnaît que bien que les questions relatives à la terre • les terres auxquelles les nouveaux (aux sols) et à la flore et à la faune (à la exploitants et ceux qui s’agrandissent biodiversité) ne limitent pas actuellement doivent avoir accès; la durabilité de l’industrie du point de vue de l’environnement, ces questions doivent • le moment auquel s’effectue l’épandage faire l’objet de recherches et d’un suivi de déjections; continus. Elle propose des recommandations relativement aux questions suivantes : xiv Environmental Sustainability and Hog Production in Manitoba

• l’inclusion de considérations relatives à La durabilité de l’environnement est la conservation de la biodiversité dans le un objectif qu’il est possible d’atteindre, processus de prise de décision; mais il ne faut pas remettre cette tâche à demain. Le défi pour le gouvernement sera • la détermination de sites écosensibles; de concevoir une stratégie de mise en œuvre qui soit acceptable pour les producteurs • la sécurité et l’hygiène du travail dans et les autres membres de la société et les entreprises de production porcine; qui permette d’assurer la viabilité sociale • la préparation aux épidémies animales; et économique de l’industrie. Dans les régions où la production de nutriants est • l’utilisation d’antibiotiques dans actuellement en déséquilibre par rapport à la l’élevage du bétail. capacité d’élimination de l’environnement, Le processus actuel d’approbation doit la Province et les producteurs doivent agir être renforcé avec pour objectif ultime rapidement et en collaboration pour rétablir la prise de décision dans un contexte l’équilibre d’ici les cinq prochaines années. de gestion de bassins hydrologiques. La Commission recommande que cela soit fait en incluant une évaluation du site en début de processus et en élargissant l’éventail de questions envisagées lors du processus d’approbation. Conservation Manitoba serait l’organisme chef de file dans ce nouveau processus. La Commission reconnaît également qu’il y a des progrès à faire relativement à la disponibilité de l’information et à la communication avec les producteurs et le public. Elle demande au gouvernement d’améliorer la collecte de données et la recherche et de mettre en place un institut de recherche sur les bassins hydrologiques. Ce rapport est une évaluation de la durabilité de la production porcine du point de vue environnemental. La Commission est tout à fait consciente du fait que certaines de ses recommandations auront des conséquences économiques pour les producteurs. Bien que ce rapport insiste beaucoup sur la réglementation et la mise en application de cette dernière, il indique que les personnes qui travaillent pour le gouvernement dans le domaine de la vulgarisation agricole ou de la planification environnementale à la ferme ou qui participent à l’élaboration de programmes qui récompensent les agriculteurs pour leurs pratiques agricoles écologiques ont un rôle d’importance égale, si ce n’est supérieure, à jouer.

xv Manitoba Clean Environment Commission

xvi 1 Introduction

1.1 Mandate and terms of reference purpose of managing hog production in an n November 2006, in accordance with environmentally sustainable manner. section 6(5)(a), (b), and (c) of The 2. The CEC investigation must include a public Environment Act, the Manitoba Minister I component to gain advice and feedback of Conservation made a request to the Clean from Manitobans. This public component Environment Commission (the Commission) should be conducted by means of public that it conduct an investigation into meetings in the various regions of Manitoba the environmental sustainability of hog to ensure broad participation from the production in Manitoba. The request included general public and affected stakeholders. the following terms of reference. 1. The CEC, as a part of its investigation 3. The CEC investigation should include will review the current environmental a review of the contents of the report protection measures now in place relating prepared by Manitoba Conservation to hog production in Manitoba in order entitled An Examination of the to determine their effectiveness for the Environmental Sustainability of the Hog Industry in Manitoba.

1 Manitoba Clean Environment Commission 4. The CEC will, as part of this • Reviewed a wide range of publications investigation, take into account the and reports relating to livestock and efforts underway in other jurisdictions sustainable agriculture. to manage hog production in a sustainable manner. • Consulted with a range of experts, including academics and federal, 5. As part of its investigation, and based provincial, and municipal government on public feedback, the commission officials. will consider various options and make recommendations in a report to the 1.3 The Report Minister on any improvements that Based on the above, the Commission may be necessary to provide for the has reached the conclusions and environmental sustainability of hog recommendations presented in this Report. production in Manitoba. The Report is divided into two sections. The At the same time the Manitoba chapters in the first section: government amended the Livestock Manure • Outline the principles of sustainable and Mortalities Managements Regulation development as they relate to to “temporarily restrict the further growth agriculture and discuss the barriers to of pig agricultural operations” until the the environmental sustainability facing Commission completed its review. the hog-production industry.

1.2 The investigation • Review the history and state of the hog- To fulfill these terms of reference the production industry in Manitoba. Commission struck two panels. The first panel, consisting of Norman Brandson, • Outline the regulations that the Wayne Motheral, and Terry Sargeant Manitoba government has put in place (Chair), held three days of public scoping to govern hog production in Manitoba meetings in January 2007. The second and place these regulations in an panel, consisting of Wayne Motheral, Terry international context. Sargeant (Chair), and Edwin Yee, carried out • Summarize the presentations and the Investigation. As a part of its work, the submissions made at the public second panel: meetings that the Commission held in • Reviewed previous government reports the spring of 2007. and all pertinent legislation and The second section of the report provides regulations. a discussion of the key issues associated • Held 17 days of public meetings with the environmental sustainability of the throughout agricultural Manitoba. industry, the Commission’s conclusions, and recommendations on those various issues. • Received 50 written submissions. The appendices of the report include the principles and guidelines of sustainable • Commissioned research papers that development found in The Sustainable have been made available to the public Development Act, the guide to public on the CEC website throughout the participation in the process (which includes Investigation. the location of the public meetings that • Visited a number of hog operations in the Commission held), and a listing of southern Manitoba. individuals who made oral and written presentations to the Commission.

2 2 Environmental sustainability and the hog-production industry

he Commission has been mandated 2.1 Environmental sustainability to conduct an “investigation into A key document for interpreting the Tthe environmental sustainability of mandate provided to the Commission hog production in Manitoba.” Such an for this Investigation is The Sustainable investigation is not possible without a clear Development Act. The Act was intended to definition of environmental sustainability implement sustainable development in the and an understanding of the sustainability of provincial public sector and promote it in the hog-production sector in particular. This the provincial private sector. It defines the chapter develops a definition of environmental environment as being inclusive of the “air, sustainability based on Manitoba’s Sustainable land, water, flora and fauna,” distinguishing Development Act and then outlines the it from the economy, which it defines as the potential barriers to sustainability facing the “global system of managing resources and hog-production sector. of producing, distributing and consuming goods and services.” Sustainability is defined as the “capacity of a thing, action, activity or process to be maintained indefinitely in

3 Manitoba Clean Environment Commission a manner consistent with the spirit of the no costs associated with the decision or Principles and Guidelines” of The Sustainable action, including externalized costs, are Development Act. Sustainable development left unaccounted for. is defined as development that meets “the needs of the present without compromising • Public participation, including forums the ability of future generations to meet for meaningful participation in decision their own needs.” making, due process, and a commitment The Principles and Guidelines for to consensus. Sustainable Development appear in full in • Access to information, which includes Appendix 1 of this report. In summary, the equal and timely access by all principles call for: Manitobans to economic, environmental, • An integration of environmental and human health, and social information. economic decisions. • Decision-making and planning processes • The need to make development decisions that are efficient, timely, accountable, in light of the needs of current and and cross-sectoral and incorporate an future generations. inter-generational perspective.

• The role of shared responsibility and • Waste minimization and substitution. understanding in decision making. • The researching, development, • The need to anticipate, and prevent or application, and sharing of knowledge mitigate, significant adverse effects of and technologies which further our decisions and actions. economic, environmental, human health, and social well-being. • The importance of conserving and enhancing natural eco-systems and Based on the language of The Sustainable other ecological resources. Development Act, the Commission concluded that in assessing the environmental • The importance of efforts to rehabilitate sustainability of the hog-production damaged resources and to include industry it is assessing if that industry can rehabilitation and reclamation measures be maintained indefinitely in light of its in future decisions. impact on air, land, water, flora and fauna. The Commission is in agreement with a • The need to recognize a global recent Quebec government investigation into interdependence and integrate the hog industry that concluded that the economic, environmental, human health “industry will be ecologically sustainable to and social factors in decision-making the extent that it is able to coexist with the while developing comprehensive and natural environment while maintaining the equitable solutions to problems. productivity, diversity, quality, and carrying The sustainable development guidelines capacity of that environment” (Bureau call for: d’audiences publiques sur l’environnement 2003, 37). • Efficient use of resources, including Agriculture and Agri-Food Canada the use of full-cost accounting to has adopted the following definition of provide better information for decision sustainable agriculture: makers. Full-cost accounting is defined as accounting for the economic, Sustainable agriculture protects the environmental, land use, human health, natural resource base, prevents the social and heritage costs and benefits of degradation of soil, water, and air quality, a particular decision or action to ensure

4 Environmental Sustainability and Hog Production in Manitoba

and conserves biodiversity; contributes century the world population is expected to the economic and social well-being of to increase by fifty per cent. Farmers must all Canadians; ensures a safe and high- also make a living and for many producers quality supply of agricultural products; commodity prices are stagnant or in decline and safeguards the livelihood and well- (Smil 2000; Tilman et al. 2002). being of agricultural and agri-foodworkers Not only are producers under an intense and their families. (Agriculture and Agri- pressure to increase production to meet Food Canada 2001, iii) the needs of a growing population, they are under pressure to shift a dramatically The Commission recognizes the mandate increasing portion of their production to for this investigation, namely to focus livestock as the growth of a global middle on environmental sustainability, could be class and urbanization drive up the demand seen as being at odds with The Sustainable for meat. From 1980 to 2002, per capita Development Act’s emphasis on integrating consumption of meat doubled in developing economic, environmental, human health, countries and the total meat supply tripled. and social factors in decision-making. In It is expected that in the next half century, the Guide prepared for participation in the the demand for meat will double (Steinfeld hearing process, the Commission noted et al. 2006). that while “the focus of this investigation Meeting that demand will test will be on the impact that hog production agriculture’s environmental sustainability. has on the sustainability of the Manitoba More specifically, it will test the environment, the Commission will integrate environmental sustainability of the economic, human-health, and social factors industrial agriculture revolution. Traditional in its analysis and recommendations.” (The agricultural practices survived for millennia; Guide is included in this report as Appendix they met sustainability’s test of time and 2.) While this report does consider those continue to provide food and fibre for factors in its analysis and recommendations much of the world’s population. But these to the extent that those factors interact practices have been challenged throughout with the environmental questions under much of the world, particularly since the review, the Commission wishes to be clear end of the Second World War, by production that this Investigation has not extensively methods that are far more intensive and examined the full range of issues that The industrialized. In industrialized nations such Sustainable Development Act envisions as as Canada, these methods constitute the being part of an assessment of sustainable dominant form of agricultural production. development. Industrial agriculture is powered by non- renewable resources and specializes in 2.2 Agriculture, livestock a series of monocultures that are often production, and sustainable produced for export markets. These changes development have allowed farmers to feed a dramatically Farmers manage the earth’s most increased and increasing world population productive lands: their activities provide (Smil 2000). most of the food needed to sustain the The great challenge facing contemporary world’s population of six-billion people. agriculture and human society as a whole They are also expected to be the stewards of is whether the coming increase in demand the soil, not only meeting current food and for food, in general, and meat, in particular, fibre needs, but ensuring that the earth’s can be met by a system that is essentially agricultural resources remain capable of working with finite resources (particularly feeding future generations. The demands of in terms of land base) without compromising the future will be exacting: in the next half the environment or public health. The issues

5 Manitoba Clean Environment Commission before this Investigation are numerous and produce more meat than developed countries complex, but they must be viewed in the (Steinfeld et al. 2006). context of this global challenge (Gibbon et The dramatic growth of the livestock al. 1995; Steinfeld et al. 2006; Tillman et al. sector has not been without environmental 2002). consequences. A recent Food and Agriculture The sustainability of intensive, Organization (FAO) report described the industrialized livestock production is central livestock sector “as one of the top two or to this challenge. The intensification of three most significant contributors to the livestock production, which currently most serious environmental problems, at provides one-third of humanity’s protein every scale from local to global” (Steinfeld intake, is a global phenomenon. By 2005, et al. 2006, xx). While the Manitoba hog 40 per cent of the world’s supply of pork industry may feel that it has been singled came from intensive production. It is out, in reality, the intensive livestock sector expected that all future growth in livestock is one that has been undergoing continuing production will be on an intensive basis environmental scrutiny throughout the (Naylor et al. 2005). A key element in this world. intensification has been dramatic increase Concerns about the environmental in the number of animals that are raised in sustainability of agriculture in Western confined, enclosed locations where they feed Canada date back at least as far as the on grains. The dramatic rise in this method nineteenth century debate as to whether of production has been driven by: the Palliser Triangle was suitable for • Declining feed grains prices coupled agriculture. The boom in immigration in with improved irrigation and feed the first decade of the twentieth century technologies that allow for increased saw millions of acres of land of varying feed production. Livestock currently eat quality brought under cultivation. Prolonged one third of the world’s cereal harvest. drought and the collapse of grain prices in the 1930s dramatically demonstrated the • Improved feed-to-meat conversion environmental and economic weaknesses of efficiencies. the type of agriculture that had evolved in the prairies in the early twentieth century as • Improved animal health and over a quarter of a million prairie residents reproduction rates. abandoned their farms (Tyrcheniewicz and Wilson 1995). In the wake of this disaster, • Low-cost transportation. the federal government established the • Trade liberalization. Prairie Farm Rehabilitation Administration, whose mission in large measure, according to • The development of information economic historian Vernon Fowke, involved technologies that allow for the “correcting the mistakes of the homestead management of global trade in livestock era” (Fowke 1957, 286). Each generation of products (Naylor et al. 2005; Steinfeld Manitoba farmers has become increasingly et al. 2006). more aware of the complexity of the There has also been a shift away relationship between their enterprises and from ruminants such as cows and sheep the environment. Many of the producers who to monogastric animals such as pigs appeared before the Commission spoke of and poultry. Throughout the world, the how much more environmentally aware they livestock sector is the most rapidly growing are in their farming practices compared to agricultural sector, although in developed their grandparents, who often, in the words countries livestock growth rates peaked of the presenters, had been unconsciously in the 1990s. Developing countries now “mining the soil” of nutrients. In short,

6 Environmental Sustainability and Hog Production in Manitoba both globally and locally, environmental safety issues) (Naylor et al. 2005; Smil sustainability is not a single practice but a 2000; Steinfeld et al. 2006; Wilson and concept that guides continued change and Tyrchniewicz 1995). adaptation. As this listing makes clear, 2.3 Agriculture and the environmental sustainability and environment stewardship involve far more than land The FAO study on livestock identified use and water use practices. It should also three major pathways through which be clear that these are issues for society agriculture affects the global environment: at large, not simply for producers, and the • The conversion of natural ecosystems to responsibility for resolving them lies with agricultural land. society, not solely with individual producers. While many producers are poorly rewarded • The movement of nutrients from for the food they produce, they receive agricultural land to aquatic and even less for implementing practices that terrestrial habitats and groundwater. sustain the environment and maintain and enhance ecological goods and services. • The movement of pesticides from It needs to be recognized that many of agricultural land to aquatic and the environmental issues associated with terrestrial habitats and groundwater intensive livestock production either do (Steinfeld et al. 2006; Tilman et al. not directly affect producers (since their 2002). impacts are felt downstream) or may not Beyond these three broad pathways, be felt within the short to medium term. intensive livestock operations, and hog Unlike most industries, agriculture is a non- operations in particular, are associated with point, as opposed to a point, producer of a number of specific environmental issues. potential contaminants: the runoff from These can be grouped under the following fields does not flow through a pipe whose headings: output can be monitored and measured. The • Water quality and quantity (this can chemical processes that take place in the include water contamination and soil are complex and not fully predictable. eutrophication due to the presence of While it may be necessary to regulate excess levels of nutrients, pathogens, individual producers, meaningful resolution and reductions in water supply). of the environmental issues facing the hog- production industry must take place at the • Air quality (including greenhouse-gas regional level (Gibbon et al. 1995; Tilman et emissions and odours). al. 2002). The Commission also recognizes that many of the issues under consideration • Changes in land use and soil degradation in this report are not unique to hog (including excess concentrations of production and that the recommendations nutrients and heavy metals). that it is making have implications for the broader livestock sector, agriculture, and the • Biodiversity (including the impact of broader society. expanding cropland for growing feed and manure spreading on the habitats of There is also no single road to other species). environmental sustainability. Arguments • Health impacts (including the human have been made that agricultural pressures health impacts of the on-farm use of on the land could be reduced by policies antibiotics and workplace health and that sought to decrease rather than increase meat consumption or move away from

7 Manitoba Clean Environment Commission intensive production methods that are dependent on non-renewable resources. The Commission recognizes that these arguments are not without their merits: however, the focus of this Investigation is an examination of the environmental sustainability of the existing hog-production sector in Manitoba.

8 3 Agriculture and the Manitoba economy

hile this Investigation is not 3.1 Farm population trends examining the economic and social From 1971 to 2000, the number of people Wsustainability of the hog-production living on Manitoba farms fell from 13 per cent industry, the Commission recognizes that it is (131,000 people) of the Manitoba population necessary to place the industry in an economic to 7 per cent (79,840 people) of the provincial and social context. The next three chapters population. While there is no current figure of the report focus on different dimensions of for the number of people living on farms, that context: the contribution of agriculture the number of farm operators in Manitoba is to the Manitoba economy, the revolution in 26,625, a decline of 7.5 percent from 2001 production methods in the North American (MAFRI). hog industry, and finally the current state of Throughout the course of this the hog industry in Manitoba. Investigation a great deal of information was provided to the Commission by various Manitoba government departments and agencies, in particular, Manitoba Agriculture, Food and Rural Initiatives, Manitoba

9 Manitoba Clean Environment Commission Conservation, and Manitoba Water 3.3 Farms and farm investment Stewardship. When unpublished material Two dominant trends in Manitoba from these departments is provided, it farming have been the decrease in the will simply be cited by department name. number of farms and the increase in the size These citations do not refer to any of the of farms. From 1996 to 2006, the number of publications listed in the references at the farms in Manitoba declined from 24,400 to end of this report. 19,054, a drop of 21 per cent. In the 15-year period from 1971 to 1996, the number of 3.2 Structure of farms farms declined by 30 per cent (because some In 1996, 60 per cent of farms were sole farms have more than a single operator, proprietorship operations, compared with Manitoba has more farm operators, 26,625, 57 per cent in 2006. In 1996, 64 percent of than farms) (2006 Census of Agriculture). farmland was operator-owned and 36 per The increase in farm size has been cent was rented by the operator, whereas in even more dramatic. In 1971 average farm 2006, 61.2 per cent was operator-owned and size was 219 hectares, in 1996 it was 317 38.8 per cent was rented by the operator. hectares, while in 2005 it was 405 hectares. As Tables 3.1 and 3.2 demonstrate, there The total capital value had gone from $13.9- has been a significant decline in the number billion in 1999 to $17.9-billion in 2006 of young farmers over the decade and a (Livestock Stewardship Panel 2000; 2006 similar increase in the role that off-farm Census of Agriculture) income plays in farm economics. Just over In 2006, total outstanding farm debt 10 per cent of Manitoba farm operators are was $5.8-billion, up from $3.5-billion in under 35 and off-farm income now accounts 1999. Table 3.3 shows the changes in assets, for close to seventy per cent of farm family liabilities, net worth, and the assets to debt total income. ratio.

Table 3.1: Farm operator age demographics. Table 3.3: Manitoba farms: assets, liability, net worth. 1996 2006 Aged less than 18 10.7 1997 2006 35 Average farm $716,500 $960,782 35-54 51 50.9 assets 31 38.4 55+ Average farm $123,900 $287,494 liabilities Source: 1996 and 2006 Census of Agriculture, Net worth $592,600 $673,289 MAFRI. Equity to asset 83 per cent 70 per cent ratio Table 3.2: Off-farm income Source: Livestock Stewardship Panel 2000, MAFRI 1996 2004 2005 2007. Some off-farm 30 -- 47.7 income 3.4 Farm income Farm income remains prone to dramatic Per cent of 43 69.4 -- total family swings. Figure 3.1 shows the total net income came farm income from 1971 to 2005. Figure 3.2 from off-farm traces the growing importance of livestock sources to the Manitoba agriculture sector. (Direct payments referred to in this figure are direct Source: 1996 Census of Agriculture, MAFRI. government to producer payments and can include revenue from crop insurance and

10 Environmental Sustainability and Hog Production in Manitoba

Figure 3.1: Total net income per farm in Manitoba 1971-2005 (in millions of dollars).

600

500

400

300

200

100

0 1971 1976 1981 1986 1991 1996 2001 Source: MAFRI.

Figure 3.2 Farm cash receipts by type in Manitoba 1981-2005 (in millions of dollars).

2500

Crop Receipts 2000 Livestock Receipts Direct Payments

1500

1000

500

0 1981 1986 1991 1996 2001 Source: MAFRI.

11 Manitoba Clean Environment Commission

Figure 3.3: Manitoba livestock type: Percent of total production value, 1996 and 2006.

60

50 1996 2006 40

30

20

10

0 Cattle Pregnant Hogs Other Dairy Poultry Mares’ livestock Urine/Horses Source: Brewin et al. 2007.

Figure 3.4: Agriculture’s industrial percentage share of the provincial gross domestic product

6

5

4

3

2

1

0 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006

Source: MAFRI.

12 Environmental Sustainability and Hog Production in Manitoba various income stabilization programs). Figure 3.3 indicates the role hog production plays within the livestock sector. 3.5 Agriculture’s significance to provincial economy Figure 3.4 sets out the annual percentage contribution of agriculture to the Provincial Gross Domestic Product from 1995 to 2006. One out of every 11 jobs depends on agriculture (down from one in ten in 2001). According to MAFRI, in 2006, 29,000 Manitobans were directly employed by the agricultural sector, down from 32,800 in 2000. In short, while agriculture remains an important part of the Manitoba economy, its revenues are subject to significant swings, ownership is increasingly concentrated, and its percentage contribution to provincial GDP and employment is either static or declining. One of the most dynamic sectors in the provincial agricultural economy has been hog production: the next chapter outlines the dramatic growth of this production sector in North America over the past half century.

13 Manitoba Clean Environment Commission

14 4 Evolution of the North American hog- production industry

he hog-production industry is one of the the following chapter describes the current most important sectors of Manitoba’s state of the industry. Tagricultural economy. It is an important market for Manitoba grains and its cash 4.1 The hog-production revolution income is valued at an estimated $834- in North America million for 2006 (Brewin et al. 2007). It is Up until the 1950s, most hogs in North also significant at the national level; Canadian America were raised from birth to market farmers received $4.3-billion from the sale weight in pens or buildings close to one of hogs (Commissioner of the Environment another (such operations are termed farrow- and Sustainable Development 2005). The to-finish operations). Hogs were usually part emergence of Manitoba as a North American of a mixed farm operation: they could be fed pork powerhouse has taken place over the cheaply on low-quality grain crop waste while past fifteen years, not without considerable their manure could be used to improve soil controversy at times. This chapter places that quality. The numbers of hogs that farmers expansion in a North American context, while raised depended in large measure on available resources, the hog-market cycle (which

15 Manitoba Clean Environment Commission generally rose and fell over a four-year • Development of a three-site (breeding, period), and the grain-market cycle (since nursery, and finishing) production farmers might increase their hog holdings system. to add value to surplus grain when grain prices were low) (Rhodes 1995; Broadway • Development of feeding strategies 2006; Naylor et al. 2006; Steinfeld et al. for each portion of the animal’s 2006). In short, they provided mixed farmers development. with meat, manure, and a measure of • Developments in antibiotics and disease diversification and risk reduction. treatment that made it possible to Over the past sixty years, that model house large numbers of hogs in confined of hog production in North America has operations. undergone a dramatic transformation, part of what has been described, on a global • Rapid genetic improvements made level, as the Livestock Revolution. For the possible by the hog’s short lifecycle. hog industry, important developments in that revolution have included: • Concentration and integration of ownership and production that allow • The use of artificial insemination large-scale producers to control (largely a post-1960 development). economic risk and pathogens (Haley • Grain-feeding of hogs (a mid-1950s 2004; Harris 2000; McBride 1997; Naylor development) and the establishment et al. 2006; Rhodes 1995; Steinfeld et al of large-scale feedmills capable of 2006). producing precise formulations. Corn is the most commonly used feed in the These practices, when combined, United Sates and Britain, while barley provided producers with more piglets per predominates in Canada and continental litter, more successfully weaned piglets, and Europe. In a significant break from the a reduction in the time it took to get them past, the feed is usually not a product to market weight. It became possible to of the farm operation that is raising the produce as much pork as had been produced hogs. in the past with fewer hogs, less feed, and fewer workers. During the 1990s, the size • U.S. agricultural policies that kept the of the U.S. breeding herd declined even as price of corn low. Feed is estimated to production increased (Benjamin 1997; Harris amount to from 50-65 per cent of the 2000). Operations that could incorporate all cost of raising a hog to market weight. of these changes could expect to produce • Year-round confinement of hogs in pork at a cost of ten per cent less than barns. traditional farrow-to-finish operators (McBride 1997). The widespread adoption • Storage of liquefied manure in a variety of these practices has led to a continuing of in-ground and above-ground storage decline in the number of farms raising hogs units. The manure would generally be and the growth of large, integrated pork applied to nearby fields. producers (Benjamin 1997; Rhodes 1995). Operations that have organized production • Development of clearly defined stages on these lines are typically referred to as of production (breeding, gestation, either intensive livestock operations (ILOs, farrowing, lactation, pre-nursery, this is the common Canadian term) or nursery, grower, and finishers). confined animal feeding operations (CAFOs, this is the common U.S. term) to distinguish

16 Environmental Sustainability and Hog Production in Manitoba them from the traditional extensive, land- farrow-to-finish operations went into rapid based forms of animal husbandry. decline in the 1990s: in 1992 they produced The industry became increasingly mobile. 65 per cent of total market hogs in the To take advantage of the low-cost corn and U.S., by 1998 this had fallen to 38 per cent soy that became a key element of hog diets (Haley 2004). Twenty years ago, 37 per cent in the post-Second World War period, the of U.S. hogs were on farms with inventories industry was initially concentrated in the of more than 1,000 head, ten years later Corn Belt states of the American mid-west. that number had risen to 71 per cent In the late twentieth century, it spread to a (McBride 1997). In 1995, the United States number of states that had not traditionally became a net exporter of pork (although been associated with the hog industry, the it continued to be a net importer of live most notable being North Carolina, where hogs, with most of its imports coming from farmers were looking for alternatives to Canada) (Benjamin 1997). Not only were tobacco farming and the cost of land and most of the hogs coming to market from labour were low. North Carolina became the large farms, they were coming to market on second largest pork producer in the United the basis of multi-year contracts between States and home to the world’s largest growers and producers. By as early as 1995, packing plant (McBride 1997; Rhodes 1995). 59 per cent of U.S. hogs were brought to As hog production became more slaughter through either integration (where predictable and profitable, it attracted the producer and processor were structurally large investors interested in the potential integrated) or multi-year contracts. The revenue stream being created by the packing industry underwent a similar industrialization of this sector. With this concentration; by 1997 six plants processed investment, producers were able to contract 29 per cent of the U.S. hog production out a portion of production and expand (McBride 1997). into processing. Companies such as Cargill, Tyson, and Premium Standard Farms 4.2 The three-site model and all- began to play a major role in all aspects in, all-out production of the industry: feed, production and In the late 1980s, the industry evolved processing (Rhodes 1995). Because the new what is termed the three-site model, which technologies were not developed for small- has largely supplanted the traditional scale production, many producers were not farrow-to-finish operation. The three sites able to make the sort of capital investment are the: required to industrialize their operations. As • Sow or breeding barns (these are home a result, the structure of the industry has to sows and gilts, which are unbred changed as dramatically as its technology. female hogs). A sow pregnancy usually In the United States a model developed lasts 115 days. In most intensive in which hog producers, often known as operations, pregnant sows are housed in integrators or contractors, contracted with what are termed gestation stalls. There smaller producers, referred to as growers, are usually 11-13 piglets a litter. to feed hogs to market weight. Under these contracts, producers supplied growers with • Nursery barns (for 5-23 kilogram management services, hogs, medicines, weanlings). and additional inputs. The producers would normally focus on the most specialized • Grower-finisher barns (for feeder hogs aspects of production, particularly farrowing, marketed at 110-115 kilogram live while growers could contract the right to run weight). nurseries or finishing operations (McBride The piglets are weaned at 18-28 days 1997; Rhodes 1995). The independent and moved to nursery barns. The piglets

17 Manitoba Clean Environment Commission have their tails docked (to prevent tail- 4.3 The impact on Canada biting) and male piglets are castrated (the The U.S. revolution in hog production meat of uncastrated male hogs has an had significant repercussions in Canada, unmarketable boar taint). The piglets in leading to the creation of a large export- the nursery barns are also referred to as oriented industry. The Canadian hog isoweans because they are being weaned in industry had been concentrating prior to the isolation from sows and from larger hogs. 1990s; for example, from 1971 to 1991, the Hogs usually can spend five to eight weeks average number of hogs per farm increased in the nursery barns (their stay in a nursery from 66 to 345 hogs, while the number barn can be as short as two weeks), and 16 of farms with hogs fell fourfold. Canadian to 18 weeks in the finishing barns. The sows hog production was concentrated in four usually recover from farrowing in 14 days provinces: Quebec, Ontario, Alberta and and produce approximately 2.2 litters a year. Manitoba. During the 1970s the hog industry The goal of the three-site system is to started to develop as a large-scale export prevent infection of the hogs. There are two industry, with live exports being more interconnected advantages to raising hogs predominant in the west than in Ontario in infection-free conditions. The first, and and Quebec. Starting in the 1970s, Quebec most obvious, reason is to avoid the serious farmers established confined hog-production financial loss that can accompany infection. systems and, by 1981, there were over Second, hogs that are free of infection gain 50 operations with over 4,600 hogs each. weight more quickly and have more lean During the 1970s that province’s share of meat. Canadian hog production went from 17 to 33 The three-site system was accompanied per cent (Broadway 2006). by the development of the all-in, all-out flow model in which all sites, locations, 4.3.1 Export industry buildings, and rooms are populated in one While the U.S. exports less than ten per day with animals that are either the same cent of its hog production, Canada exports age or are sows at the same point in their over fifty per cent of its production. In pregnancies. When the animals leave, again 2004, eight million of the 100-million hogs on the same day, the room is cleaned, slaughtered in the U.S. came from Canada disinfected and left empty for a short period (two-thirds of them as feeders, one-third before new animals are brought in. Under as slaughter animals). The finishing usually ideal conditions, the operations are located takes place in Corn Belt states, with the in well-isolated areas characterized by a low slaughter animals being shipped to locations density of hogs in the region (Harris 2000). that have hog deficits. In 1989, Canada The three-site system is a form of exported just one million hogs to the U.S. biosecurity response to the fact that (16 per cent feeders, 84 per cent slaughter diseases are more easily transmitted when animals). The number and composition of hogs (or any other animals) are raised in Canadian exports has changed dramatically: high densities. Many hog operations employ the numbers are up and the feeder share of additional biosecurity measures, including those numbers is up significantly. Canada requirements that people have no contact accounts for 99 per cent of the hogs with other hogs for 48 hours prior to imported to the United States with more entering a barn and that they shower on than half of those animals entering the U.S. entering and leaving the barn. Operations through North Dakota in 2004. By that year often have quarantine barns for incoming 18 per cent of the feeders in Iowa came from hogs. Canada (Haley 2004).

18 Environmental Sustainability and Hog Production in Manitoba 4.3.2 Growth factors 4.4 Social conflict and The growth in the Canadian hog environmental concerns industry, particularly in the Canadian west, The industrialization and expansion of was assisted by two important factors in hog production in North America has given the 1990s: the repeal of the Western Grain rise to a number of social and environmental Transportation Act (WGTA), and the low controversies. Questions have been asked value of the Canadian dollar in relation as to whether smaller producers, who to the U.S. dollar. The WGTA was the last lacked contractual agreements with large vestige of the Crow Rate, which had been producers or processors, would be forced to established in the late nineteenth century shoulder more of the cost of price swings to provide Prairie farmers with freight rate and whether they would lose access to assistance for shipping grain by rail to markets during periods of over-production. Canadian ports. It was viewed by many in More significantly, the siting of intensive the livestock industry as a barrier to the livestock operations became increasingly development of a pork industry in western controversial. In many localities, groups of Canada since, under its provisions, it was residents formed organizations to oppose cheaper to ship grain to Quebec where it proposed hog-production operations. could be fed to hogs than to ship processed While they identified a wide range of pork similar distances (Broadway 2006). specific concerns, particularly relating to The repeal of the WGTA created odour and water, overall, opponents spoke market problems for Prairie grain farmers, of their concern as to whether existing particularly in Manitoba, many of whom environmental regulations could ensure were hit with what amounted to a $40 sound environmental conduct. This critique an acre increase in transportation costs. was coupled with an emphasis on the need Conversely, the end of the WGTA effectively for public participation in the decision- reduced hog production costs in Manitoba by making process. $10 a hog (Grier et al. 2007). In response to In response, producers have argued the loss of the WGTA, Manitoba producers, that, since they operate environmentally assisted by the Manitoba government, sound state-of the-art facilities, they do developed a provincial hog-production not constitute a threat to the environment. strategy. It is their position that the key decision- Because the price for Canadian hogs is making questions revolve around land use as largely set in the United States, the low opposed to environmental regulation. While Canadian dollar of the 1990s created a they acknowledged odour to be an issue, premium for Canadian producers. The more they took the position that this was being recent increase in the Canadian dollar has addressed through a variety of technical reduced the profitability of the Canadian developments and that, furthermore, some industry, causing it to lose ground in the odour was a fact of rural life. Where the non-U.S. export market (Haley 2004). producers argued that they were bringing A subsidiary factor in the rise of the jobs and development to marginalized industry in the late 1990s was the 1997 communities, their opponents made a case expiration of a U.S. countervailing duty that that the benefits of such development were had limited Canadian access to the U.S. hog unlikely to be retained in such communities, market. since the industry was replacing labour with machinery that was not purchased locally. These conflicts have led to a variety of outcomes: some jurisdictions have welcomed the operations and amended

19 Manitoba Clean Environment Commission laws to ease their arrival, while others companies were combining to keep prices have opposed the development. Perhaps down. Participation in the board, initially the most significant development was the voluntary, became mandatory in the 1970s moratorium on industry expansion that (Broadway 2006). North Carolina imposed in 1997. In 2002, Quebec responded to the growth of the hog 4.5.1 Hutterite colonies and Manitoba farming industry and citizens’ concerns by hog production declaring a moratorium on the expansion of Manitoba’s Hutterite Brethren have been existing hog farms and on the development a mainstay of the province’s hog-production of new hog farm operations; it remained in industry for well over half a century. Since place until 2005. The expansion of the hog arriving in Manitoba in 1918, the Hutterites industry in Manitoba has also generated have been able to preserve their communal social conflict. The most common conflicts lifestyle by developing rural colonies that have arisen at the municipal level when engage in agricultural activities. Currently local residents have opposed proposals to 115 colonies in Manitoba raise hogs, with an establish intensive hog operations in their annual production of 1.4 million or 15 per municipality (Benjamin 1997; Broadway cent of total provincial production (MAFRI). 2006; Constance and Bonnano 1999; Manitoba Pork Study Committee 1994; Novek 4.5.2 The Manitoba expansion 2003; Rhodes 1995). In 1993, when the industry was on the brink of its most recent expansion, the 4.5 The expansion of the Manitoba pork industry exported 70 per cent of its production of 2.3 million hogs a year. Manitoba industry There were 2,334 commercial enterprises Throughout the twentieth century producing hogs (446 farrow to weanling, Manitoba agriculture was dominated by 311 farrow to weanling or finish, 666 farrow the export-oriented wheat sector. Hog to finish, and 800 finishing operations). It production took place in the context of was recognized that the industry exported a mixed farm, operation with inventories a large percentage of live hogs relative peaking at 668,000 during WWII and to pork (in 1993 live hogs accounted for declining to 400,000 in the post-war period. 42.4 per cent of hog and pork exports, In the late 1960s, in response to a dramatic up from 32.6 in 1989). Manitoba packing decline in the demand for Canadian grains plants, whose combined capacity was 1.8- on the international market, the federal million hogs, were running from 15 to 35 government encouraged Manitoba farmers to per cent below processing capacity. Of the increase their hog and cattle production. The farms that shipped live hogs, 76.5 per cent number of hogs in Manitoba increased from of the producers accounted for only 19.5 526,000 in 1968 to 884,000 in 1970 (Ryan per cent production, while 4.9 per cent of 1977). Shortly thereafter, grain demand the producers (101 of the province’s 2,334 increased and hog production declined producers) accounted for 44.7 per cent of (Wilson and Tyrchniewicz 1995). production (Manitoba Pork Study Committee Prior to 1990, Manitoba hog production 1994). was characterized by fluctuations that The late 1990s saw the emergence were largely based on price, with producers of a large-scale hog-production sector in entering and exiting production in rising Manitoba. The industry was intended to and falling waves. Hogs were marketed capitalize on what was sometimes described through a hog marketing board, which as the Manitoba advantage: cheap land, had been established in the 1960s by cheap feed, and a low-population density the Manitoba government in response in rural Manitoba (Broadway 2006). The to producer complaints that the packing

20 Environmental Sustainability and Hog Production in Manitoba framework for this expansion was proposed individually. The government also passed in the 1994 report Manitoba’s Pork Industry: legislation establishing the Manitoba Pork Building for the 21st Century Prospects Council (MPC). The Council is funded by a and Challenges, prepared by the Manitoba mandatory levy of 80 cents per slaughter Pork Study Committee (Dr. Clay Gilson, hog and export breeding stock and 19 cents Dr. David Donaghy, and Gerry Moore). At per export weanling. The MPC currently has the time of the study’s completion, it was approximately 1,400 members. The Council is estimated that Manitoba’s pork industry involved in a variety of activities including (from producers through to retailers) funding research, member education, quality employed approximately 12,000 people assurance and food safety, and lobbying. and generated $500-million in revenues. The provincial government also The report recommended that the province concluded negotiations with Maple Leaf adopt a strategy aimed at doubling pork Foods that led to the opening of a new production and processing in a five-year slaughter and processing plant in Brandon. period. While the industry had doubled over While Schneider Foods had been projecting the previous 15 years, it was felt that the an expansion of its Winnipeg operation, existing structure and approaches would not Maple Leaf Foods purchased the company in allow for the anticipated expansion, which 2001 and placed the expansion on hold. it was estimated would cost approximately By 2000, the three-site model was $350-million. Of this, $300-million would common in large-scale hog operations in be directed to the production side of the Manitoba. In a typical three-site operation industry and $30-million to $60-million in Manitoba: would be invested in a new slaughter plant. • Site 1 would have a sow or breeding It was estimated that a 1,000 sow farrowing barn with 1,200-1,500 sows. operation would cost $1.8-million, with the farmer requiring $700,000 of equity. It was • Site 2 would have four to five nursery recognized that it would be difficult for most barns with 2,000-2,500 weanlings each. farmers to make this sort of investment, and that a variety of arrangements, such • Site 3 would have three to five grower- as feed companies providing the hogs and finisher barns with 2,000 finishers each. the feed and the farmer providing the barn, Such operations might have a total of 8-11 might be necessary. Government could assist barns and 15,500 to 22,500 hogs on three in the expansion through loans extended sites. (Manitoba Government 2000a). through the Farm Credit Corporation, the In this model, the hogs are raised Manitoba Agricultural Credit Corporation, indoors, in barns with slotted floors. The and Manitoba Grow Bonds (Manitoba Pork feces and urine fall through the slots Study Committee 1994). and collect in under barn containment The Manitoba government assisted in units that are flushed into large manure the development of an industrial hog sector storage facilities (either above-ground or in a number of ways. In 1994, it introduced in-ground). An alternative model, often a Livestock Waste Regulation and The Farm referred to as hoop barns or enviro-tech, Practices Protection Act and Farm Practices has also developed. It involves raising Protection Board (all of which are discussed hogs in hooped structures that resemble at length in subsequent chapters). In 1996, greenhouses. The structures are usually it did away with the single-desk selling covered with polyethylene on the sides and system, establishing a new system under throughout much of the year, the ends of which producers could either market their the structures are open to the elements. hogs through third parties, particularly, the These systems use what is termed a deep- Manitoba Pork Marketing Cooperative, or bedding manure management system in

21 Manitoba Clean Environment Commission which the hogs’ bedding is comprised of Table 4.1: Annual expansion of barn spaces for composting organic matter such as straw. sow and grow/finish hogs (1995-2006). The hogs will use a portion of the bedding for sleeping and portion to urinate and Year Sow Grow/Finishers defecate. The straw absorbs the urine, while 1995 13,980 93,200 the composting process serves as a heat 1996 16,286 69,116 source for the hogs. When the hogs are sent 1997 25,545 121,900 to market, the manure is removed, usually 1998 28,185 91,293 with a front-end loader to a location where it can be composted. This method accounts 1999 18,840 79,250 for approximately 10 per cent of Manitoba 2000 30,995 137,587 production (MAFRI 2007). 2001 54,265 132,731 Manitoba hog production grew from 1.3 2002 31,700 87,160 million in 1980 to 8.8 million in 2006. The 2003 16,250 69,212 biggest increase came in the last decade when production increased from 4 million 2004 170 13,183 in 1997 to 8.8 million in 2006. Figure 4.1 2005 2,720 68,467 charts the growth of Manitoba production. 2006 1,800 43,453 While hog-production numbers have Total 240,736 1,006,552 climbed steadily over the past quarter century, the value of hog production has Source: MAFRI. been variable, reflecting the four-year cycle in pork prices. Figure 4.2 outlines the value of Manitoba hog production since 1960. Table 4.1 outlines the annual increase in capacity over the past 12 years. The table shows the number of barn spaces that were created each year for sows and grow/ finisher hogs. As the table makes clear, over the last five years there has been a decline in the rate of expansion of sows, while the expansion of grower/finisher hogs peaked in 2001, but remains significant. Manitoba Agriculture, Food and Rural Initiatives (MAFRI) estimates that the expansion of the hog industry generated $875-million worth of construction over the last 11 years.

22 Environmental Sustainability and Hog Production in Manitoba

Figure 4.1: Manitoba hog production, 1960 to 2006

10

9 Millions 8

7

6

5

4

3

2

1

0 1960 1965 1970 1975 1980 1985 1990 1995 2000 2005 Source: Statistics Canada: Agriculture and Agri-Food Canada; Canadian Food Inspection Agency; Manitoba processing plants.

Figure 4.2: Manitoba hog-production value (thousands of dollars) 1960-2005.

1,200

1,000 Thousands

800

600

400

200

0 1960 1965 1970 1975 1980 1985 1990 1995 2000 2005 Source Statistics Canada; Agriculture and Agri-Food Canada; Canadian Food Inspection Agency; Manitoba processing plants.

23 Manitoba Clean Environment Commission

24 5 Current state of Manitoba hog industry

og production is now the largest and and livestock combined. From 1997 to 2006, most dynamic single commodity in Manitoba’s share of total Canadian hog farm HManitoba’s agricultural economy. cash receipts rose from 16 to 24 per cent. Manitoba is also the country’s leader in hog Profit margins for hog producers remain slim: production and hog exports. In 2006, hog from 2004-2006 Manitoba producers made production was the largest source of farm between nothing and $2 per head profit. receipts of any single agricultural commodity Manitoba packers lost between $45- to $50- in the province. In that year, Manitoba’s hog million between 2004 and 2006 (Grier et al. production of 8.8 million head was worth 2007). $834-million (Brewin et al. 2007). Production has become dramatically According to the George Morris Centre, concentrated, with 20 per cent of producers from 2004 to 2006, the average farm cash accounting for 78 per cent of production (See receipts for Manitoba hog farms were $905- Table 5.2). From 1995 to 2004, the annual million. This accounted for 51 per cent of growth rate of production in Manitoba hog total livestock farm cash receipts and 26 per production was 12.6 per cent, up from 4.6 per cent of total farm cash receipts from crops cent for the previous decade. The growth rate

25 Manitoba Clean Environment Commission has slowed in recent years, dropping to 2 per Table 5.1: Trends in number of hog farms, hogs cent in 2006 (Brewin et al. 2007). per farm, and total hog production. Canadian and particularly Manitoba hog production has proven to be more efficient January 1990 2000 1, 2007 than U.S. production in terms of hogs per litter and hogs per breeding animal. This has Manitoba hog farms 3,150 1,450 1,280 been attributed to the cooler weather, which Average number of 388 1,290 2,596 inhibits disease and increases lactation. hogs per farm The degree to which barns are well spaced Hog production in 3.2 4.8 8.8 from one another also reduces the risk of hogs million million million diseases travelling from one barn to another. Finally, since the industry is not as well Source: MAFRI, Finding Common Ground 2001. established in Canada as it is in the United The 8.8 million hogs a year figure States, the diseases associated with the does not represent the number of hogs industry are also not as well established on Manitoba hog farms at any one time, (Grier et al. 2007; Haley 2004). A number since most of the hogs produced are being of studies have argued that the Canadian marketed by seven months of age. Four production advantage may apply more to million weanlings are marketed within breeding, gestation, and nursery operations, weeks of their birth. As a result, at any one and that finishing is cheaper to carry out time, there are approximately three million in the United States where feed costs are hogs on Manitoba farms. Figure 5.1 shows low and the finishing operations are in close the average number of hogs per farm and proximity to processing plants (Broadway number of hog farms in Manitoba. 2006; Haley 2004; Tyrchniewicz and Gregory 2003). 5.2 Concentration of production According to the 2006 census, 768 5.1 Decline in number of hog Manitoba farms were predominantly hog operations operations (farms where hogs account for 50 At the start of 2007, Manitoba had per cent or more of total potential receipts). (according to Statistics Canada), 1,280 hog These operations owned 355,370 of the farm units. This represented a decline of 23 7,718,571 hectares of farmland in Manitoba per cent since 2002. During the same period, (Grier et al. 2007). In 2006, just under 21 the number of hog farms in Saskatchewan per cent of the operations (244 operations) and Alberta dropped by 27 and 34 per cent were responsible for 78 per cent of the hogs. respectively, while the national decline Twenty per cent (240) had fewer than 20 was 21 per cent (Grier et al. 2007). Table hogs on the farm (Brewin et al. 2007). As 5.1 outlines the changes in the number Table 5.2, shows, 58 per cent of Manitoba of operations and the number of hogs in hog farms accounted for only 6 per cent of Manitoba over the past quarter century. the province’s hog population. As will be The fact that an operation has ceased to discussed in Chapter 9, this concentration raise hogs is not necessarily a sign that the has environmental consequences. operation has closed, since many of the smaller operations are mixed farm operations 5.3 Structure of the Manitoba that may have simply moved out of hog industry production. The hog-production sector has undergone a dramatic change over the past 15 years, in large measure reflecting the transformation of the North American hog-production industry. Key elements

26 Environmental Sustainability and Hog Production in Manitoba

Figure 5.1: Average number of hogs per farm and number of hog farms in Manitoba, July 1, 1986- 2006. 4,000

3,500 Hog farms 3,000 Hogs per farm

2,500

2,000

1,500

1,000

500

0 1986 1988 1990 1992 1994 1996 1998 2000 2002 2004 2006 Source: MAFRI. of this change have been: the rise of the contracts with smaller operators to organize three-site production system, the decline production. in the number of operators raising hogs, Three large hog-production companies, the increase in the size of hog operations, Elite Swine, Hy-Tek, and Puratone, have the consolidation of production under the played a key role in developing the industry leadership of a limited number of production in Manitoba. These companies favoured companies that are linked to other steps the three-site production method, built in the production process (typically feed many of the original barns, and entered and processing), and the use of production into production agreements with farmers to operate nursery and finisher barns for their

Table 5.2: Manitoba hog farms by herd size.

Hog farms Total hogs Herd size Number Per cent of total Number Per cent of total All farms reporting 1,188 100 2,932,548 100 1 to 99 327 27.5 5,901 0.2 100-499 212 17.8 58,314 2.0 500-999 156 13.1 110,575 3.8 1,000-2,499 189 15.9 289,309 9.9 2,500-3,999 60 5.1 179,167 6.1 4,000 and more 244 20.5 2,289,282 78.1

Source: Statistics Canada, Census of Agriculture, 2006: special tables sponsored by Manitoba Pork Council.

27 Manitoba Clean Environment Commission hogs. Under this development model, it in south-east Manitoba. In 2006, the RM was common for barns to be built relatively of La Broquerie had 445,683 hogs and the close to feed mills. By 2006, these three RM of Hanover had 388,905 hogs (Rawluk companies controlled 40 per cent of the sows and Flaten 2007). Figure 5.2 illustrates in Manitoba (Grier et al. 2007). the distribution of Manitoba hog farms While each company has a different by type and agricultural region. Map 5.1 and evolving business model, they often shows Manitoba’s agricultural regions. Map own or control transport fleets, genetics 5.2 shows the distribution of Manitoba hog laboratories, construction companies, production facilities as documented by the and manure-management companies. Manitoba Pork Council. Some companies focus on their own hogs, Manitoba’s Hutterite colonies retain raising them either in barns they own or a significant share of Manitoba’s hog in barns that are owned by local farmers production. Unlike the other large-scale (or investor groups), while others focus on producers, the Hutterite colonies do not managing hogs in barns that are owned by contract out production or maintain three- investors or local farmers. In most cases, site operations. Holding 35 per cent of regardless of ownership, the hogs are raised the provincial sow base, they constitute according to a regime stipulated by the the main farrow-to-finish operations in production company. Veterinary services, Manitoba. Over the past decade most hog marketing, preparation of manure colonies have doubled the number of sows management plans, and the application that they house—moving from a range of of manure are usually arranged by the 600-to-800 to a range of 1,000-to-1,200 management company or supplied by the (Grier et al. 2007). Most of the hogs sold for marketing company employees. Management slaughter in Manitoba (approximately 90 per agreements generally require the barn cent) are sold with some form of contract or owners to use feed produced by the hog- marketing agreement (Grier et al. 2007). production company. Elite Swine told the Commission that 5.3.1 Hog farms with field crops it owned or managed 109,000 sows and As Table 5.3 indicates, larger hog- 1.9 million market hogs, with two-thirds production operations are less likely to of its production in Manitoba (all three of have their own field crops and are more the large hog-production companies have dependent on access to the fields of grain international connections). Elite Swine is producers for manure disposal than smaller currently restructuring its production to operators, while mid-size operators are the reduce the number of sows that it owns most likely to own crop fields. and manages. Hy-Tek representatives stated they had 57,000 sows and raised one million 5.4 Slaughter hogs a year, 65,000 of which were raised to In 2006, 4.3 million hogs were market weight. Puratone representatives slaughtered in Manitoba, 3.4 million of told the Commission that it owns, operates, which originated in Manitoba. It should and manages 46,000 sows and produces and be noted that not all hogs slaughtered manages one million hogs, one half of which in Manitoba come from Manitoba. In are raised to market weight. 1999, 515,000 of the 1.9 million hogs The fact that all three companies were slaughtered in Manitoba came from Alberta, developed out of a base in southeastern Saskatchewan and Ontario, while in the Manitoba played an important role in first half of 2007, the proportion of out- developing the industry in that region. of-province hogs slaughtered in Manitoba Twenty-eight per cent of Manitoba hogs are increased from nine per cent to 15 per concentrated in two rural municipalities cent, due in large measure to the closure

28 Environmental Sustainability and Hog Production in Manitoba

Map 5.1: Manitoba’s agricultural regions.

Source: MAFRI Figure 5.2: Number of Manitoba hog farms by type and agricultural region, 2006.

350

300

250 Less than 20 pigs

Number of hog farms Number of 200 Farrow-Finish Feeding-Finishing 150 Farrow-Wean

100

50

0 1 2 3 4 5Agricultural6 regions7 8 9 10 11 12 Source: Brewin et al. 2007

29 Manitoba Clean Environment Commission

Map 5.2: Distribution of Manitoba hog operations.

0 25 50 75 100 125 150 Kilometers 0 15 30 45 60 75 90 Miles

Source: Manitoba Pork Council.

Table 5.3: Manitoba hog farms with crop fields (including hay).

Percentage of Number of hog farms with Herd size farms crop fields Acres Hectares All farms 868 100 1,048,459 424,297 reporting 1 to 99 243 73.1 86,669 35,074 100-499 175 74.3 102,683 41,554 500-999 128 82.5 97,119 39,303 1,000-2,499 125 82.1 119,376 48,310 2,500-3,999 39 65.0 62,727 25,385 4,000 and more 158 64.8 579,885 234,671

Source: Statistics Canada, Census of Agriculture, 2006: special tables sponsored by Manitoba Pork Council.

30 Environmental Sustainability and Hog Production in Manitoba of a Saskatchewan packing plant (Livestock The number of hogs slaughtered in Stewardship Panel 2000, Grier et al. 2007, Manitoba has doubled over the past ten MAFRI 2007). During this period, export years due to the opening of the Maple Leaf of Manitoba hogs to the United States was Foods processing plant in Brandon in 1999. approximately 10 per cent higher compared Figure 5.3 shows the Manitoba hog slaughter to the same period the previous year (MAFRI for 1981 to 2006. 2007). The closing of a Saskatchewan facility The 2000 Finding Common Ground report and the proposed closing of Winnipeg prepared for the Manitoba government operations will put pressure on Manitoba anticipated that through an expansion of producers who wish to have their animals the Schneider Foods plant in Winnipeg and slaughtered in Manitoba. the addition of a second shift at Maple Leaf Canadian slaughter capacity has not kept Foods in Brandon, Manitoba would soon pace with the dramatic increase in Canadian have a slaughter capacity of ten million hog production, increasing by 38 per hogs, four million more than the capacity cent from 1995 to 2003, while production in 2000. It estimated that an investment of increased by 66 per cent during the same $750-million in barns, equipment, breeding period. Key to this has been the fact that stock and land would be needed to produce Canadian plants have often not been able to enough hogs to meet that slaughter capacity offer prices that are competitive with those level. However, the anticipated increase in offered by U.S. plants (Haley 2004). During slaughter capacity has yet to materialize. the 1970s and 1980s, Manitoba lost much Maple Leaf Foods purchased Schneider of its slaughter and processing capacity, so Foods and is in the process of closing rather that by the 1990s, hogs were slaughtered at than expanding its Winnipeg slaughter the Springhill plant in Neepawa and at the operations. A second shift is planned for Schneider Foods plant in Winnipeg.

Figure 5.3: Manitoba hog slaughter statistics (number of hogs slaughtered and value of slaughter), 1981-2006.

5,000 Manitoba Origin Slaughter in 4,500 Canada

4,000 Total Federal and Provincial Thousands Slaughter in Manitoba 3,500 Estimated Value Of Hogs 3,000 Slaughtered in Manitoba 2,500

2,000

1,500

1,000

500

0 1981 1986 1991 1996 2001 2006 Source: MAFRI.

31 Manitoba Clean Environment Commission the Maple Leaf Foods plant in Brandon but was up from 2005 to 2006, revenue was has yet to commence operation. When the down. The exported weanlings are usually second shift is added, the plant is expected sold shortly after birth at a weight of seven to have a capacity of 90,000 a week or kilograms (Brewin et al. 2007). Figure 5.4 4.68 million a year. This expansion has to outlines the trends in Manitoba exports of be balanced with a recognition of the fact slaughter hogs and weanlings. that slaughter capacity is being reduced Pork exports and revenue were both in Saskatchewan and Winnipeg. The lack down in 2006 from the previous year, with of sufficient slaughter capacity is one of Manitoba exporting $409-million worth of the causes behind the high volume of hogs pork, down 13 per cent from the previous exported to the United States. year. The volume of pork export dropped by 7 per cent compared to the previous year. 5.5 Export While the United States is essentially The Manitoba pork industry is an export the sole market for Manitoba hogs, the pork industry—whether they are sold as live market is more diverse. In 2005 and 2006, animals or as pork, 80 per cent of Manitoba the three major pork customers were the hog production leaves the country (Grier et United States (34 per cent) Japan (28 per al. 2007). In 2006, Manitoba exported 5.4 cent) and Mexico (17 per cent) (Grier et al. million hogs (4.1 million weanlings and 1.3 2007). million market hogs) to the U.S., up from Exports sales to the U.S. take place five million the previous year. The total under a variety of arrangements including value of the 2006 hog exports was $374- retained ownership, contracts and third- million (the weanling and slaughter hogs party brokers, as well as sales on the cash were valued at $187-million each). The total or spot market (although these constitute a value of the 2005 export was $418-million minority of sales) (Grier et al. 2007). (MAFRI 2007)—in short, while the volume

Figure 5.4: Manitoba exports of slaughter hogs and weanlings (in number of hogs), 1990-2006.

4,500,000

4,000,000

3,500,000

3,000,000 Slaughter hogs Weanlings 2,500,000

2,000,000

1,500,000

1,000,000

500,000

0 1990 1992 1994 1996 1998 2000 2002 2004 2006 Source: MAFRI.

32 Environmental Sustainability and Hog Production in Manitoba

Figure 5.5 charts the value of Manitoba Table 5.4: Economic activity generated by pork exports from 1995 to 2006. Manitoba hog farms. 5.6 Impact on Manitoba economy Canada (includes The George Morris Centre conducted Manitoba an economic analysis of the Manitoba hog Manitoba figures) production on behalf of the Commission for Indirect taxes on $27 million $36 million this Investigation. As a part of that review, production it applied the Statistics Canada Input-Output Wages, Contracts, $504 million $723 million Model to the industry. This is a model that Benefits and Other incorporates all producer and processor Income input activity: grain farms, feed mills, and Direct employment 1,382 1,382 other suppliers. Table 5.4 summarizes the in the industry key findings of that analysis. Indirect employment 3,394 5,777 According to this analysis, in Manitoba, in the industry the hog-production sector generates $1.7- Total employment in 4,775 7,159 billion in economic activity (defined as the industry total revenue generated by the industry as Total economic $1.7 billion $2.2 billion well the revenue generated by its supplier activity sectors as a result of the industry), nearly 5,000 jobs, and pays $500-million in wages, Source: Grier et al. 2007 contracts, benefits and other income. summarized in Table 5.5. It should be noted The economic activity generated by that because there are so few processors in the Manitoba pork packing industry is Manitoba, the Statistics Canada model, for

Figure 5.5: Manitoba pork export values in millions of dollars, 1995-2006. 600

Millions 500 The United States All Countries 400

300

200

100

0 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006

Source: MAFRI.

33 Manitoba Clean Environment Commission reasons of confidentiality, does not provide million tonnes of barley, 0.1 million tonnes direct and indirect employment figures. of canola meal, 0.4 million tonnes of corn, However, the George Morris Centre estimates 0.2 million tonnes of soy meal, and a small there are likely to be 2,500 people directly portion of oats. According to the MPC, an employed in the industry in Manitoba and additional 1.3 million tonnes of feed would 1,200 indirectly employed in the industry. be needed to bring all Manitoba hogs to slaughter weight. The George Morris Centre Table 5.5: Economic activity generated by estimated that the industry was a market for Manitoba pork packers. about $500-million in grains and feedstuffs Manitoba Canada (Grier et al. 2007). Indirect taxes on $12 million $36 million production 5.7 Issues facing the industry An inventory of the major issues facing Wages, contract, $360 million $723 million the industry are: benefits and other income • Rising feed costs. Direct employment n/a n/a in the industry • Labour shortages. Indirect employment n/a n/a • Slaughter capacity and cost. in the industry Total employment in 3,713 5,607 • An appreciating Canadian dollar. the industry Total economic $1.2 billion $1.7 billion • Access to export markets. activity 5.7.1 Feed costs Source: Grier et al. 2007. Feed costs have been estimated as constituting between 50 and 65 per cent The George Morris Centre identified the of production costs. One of the primary following impacts for the hog-production drivers of the expansion of the Manitoba and processing industry in Manitoba: hog-production industry was the search for • Total jobs generated in Manitoba: 7,500 a market for Manitoba grain. Ready access (hog farming plus direct estimate for to low-cost Manitoba grain, particularly packing). barley, was seen as a key element in the Manitoba advantage. However, in recent • Total wages, contracts benefits, and years that advantage has been disappearing, other income $610-million. as U.S. corn yields continue to rise while • Total economic activity: $2 billion. the corn prices paid by U.S. hog producers fall. According to the George Morris Centre, this provides Minnesota producers an eight- 5.6.1 Feed dollar-a-head feed advantage over Manitoba According to the Manitoba Pork Council hog producers. (MPC), the Manitoba hog-production In coming years, this may be offset industry consumes more than two million by the growing ethanol market, which is tonnes of feed per year, valued at $450- driving up the price of corn in the U.S. million. One quarter of the feed consumed While the growth of ethanol production in by the industry is imported from the United Canada is also increasing, the possibility States. Ration ingredients vary from year to exists that the overall impact will be to year, depending on input costs. The MPC told reduce the U.S. feed advantage (Grier et al, the Commission that, in 2005, the ration 2007). The hog industry itself believes that consisted of 0.2 million tonnes of wheat, 1.0

34 Environmental Sustainability and Hog Production in Manitoba the biofuels sector will drive up the price of Table 5.6: Relative packing plant sizes, Canada feed. and U.S. Canadian Food Inspection Agency (CFIA) regulations have also affected the Manitoba U.S. Canada Quebec hog industry in two ways that relate to the Average Daily 13,000 3,200 2,700 environmental impact of the phosphorus Capacity content of the manure that the animals Five largest average 21,000 8,4000 5,500 excrete. The CFIA’s decision to classify daily capacity a form of barley with highly available # plants>40,000 20 3 0 phosphorus as a novel feed has brought that head per week grain’s development to a halt. If such a feed were to become available, it would eliminate Source: Grier et al. 2007. the need to add dicalcium phosphate to has recently undergone a significant feed, thus reducing producer costs and the rationalization, currently two processors phosphorus levels in hog manure. Second, have 51.8 per cent of the daily kill capacity the CFIA has not adjusted its phosphorus (Livestock Stewardship Panel 2000, MAFRI). requirements for hog feed to take into As noted above, the closing of slaughter account the impact that the addition plants across the prairies will leave Manitoba of phytase has on the level of available producers competing with other prairie phosphorus in hog diets (the potential producers for access to Canadian slaughter impact of phytase is discussed in Chapter plants. 9). Such an adjustment would also reduce producer costs and the phosphorus levels in 5.7.4 An appreciating Canadian dollar hog manure. When the Manitoba hog-production industry expanded in the mid-1990s, the 5.7.2 Labour Canadian dollar was trading at two-thirds Labour accounts for 10 per cent of the the value of the U.S. dollar, providing cost of hog production (and up to 20 per the Canadian sector with a considerable cent of the non-feed costs). Manitoba wage benefit. As the relative value of the dollar rates for livestock workers are two dollars has increased, this benefit, which was an hour higher than those paid in the enjoyed by both producers and packers, has Midwestern United States. This differential disappeared. provides U.S. producers with a one-dollar-a- head advantage. 5.7.5 Access to export markets Unlike other major pork producing 5.7.3 Slaughter capacity and price countries, Canada is dependent on exports. Larger packing plants enjoy considerable Canada exports 50 per cent of its production, economies of scale and U.S. plants have and Manitoba exports 80 per cent of its considerably more capacity than Canadian production. By comparison, the U.S. exports plants, particularly if they run double 10-13 per cent of production, the European shifts. This can amount to a five-dollar-a- Union exports 7 per cent, and Brazil 25 head advantage for U.S. processors. Table per cent. The Food and Agriculture Policy 5.6 outlines the difference in scale between Research Institute estimates that despite Canadian and U.S. packing plants. the various challenges facing the Canadian The U.S. packing industry was highly hog industry, Canadian exports, after centralized in 2001 and remains so today, experiencing a short-term downturn will with four firms controlling 61.4 per cent of continue to grow over the coming decade daily slaughter capacity (up slightly from 60 (Grier et al. 2007). per cent in 2001). In Canada, the industry

35 Manitoba Clean Environment Commission One of the most immediate challenges to Canada’s access to the U.S. market is the U.S. Country of Origin Labelling (COOL) law set to come into effect by October 1, 2008. This law will require U.S. retailers to label all fresh pork and beef as to their country of origin. U.S. packers will be faced with two choices: 1) stop purchasing Canadian hogs or 2) segregate Canadian hogs within their packing operations, a measure which will increase their costs and drive down the price they are prepared to pay for Canadian hogs.

36 6 Barriers to sustainability

he Commission has been mandated further identified the potential barriers to to carry out an investigation of the sustainability. Tenvironmental sustainability of the This chapter will provide a brief overview hog-production industry. As noted in Chapter of the issues and their implications for the 2, the Commission has concluded that in Manitoba hog-production industry. The assessing the environmental sustainability following chapter will outline the regulations of the industry, it is assessing if it can be that the Manitoba government has put in maintained indefinitely in light of its impacts place to address the risks that these factors on air, land, water, flora, and fauna. Given represent in Manitoba. It should be made the fact that potential impacts on water clear that, simply because a risk has been quality and quantity figure so significantly identified in this chapter, does not mean that in any discussion of the environmental it necessarily exists in Manitoba or that it is sustainability of the hog industry, the not being managed in a way that mitigates Commission has adjusted the order of these potential damage. topics to place water at the head of the list. Under each of these headings, the Commission

37 Manitoba Clean Environment Commission 6.1 Water be transported, a fact that can lead to geographically concentrated application of 6.1.1 Water quantity manure to land. Hogs require varying amounts of The method of application, particularly drinking water, dependent upon the stage of liquefied manure, can have a significant they are at in the production process and impact on the rate of nutrient loss from the conditions in which they are being the field. Losses are best controlled when housed. Water is used to cool hogs in the manure is either injected directly barns in summer and for cleaning hog into the soil or is incorporated shortly housing facilities. Most of Manitoba hogs after application. Losses are greater when are produced in systems that store manure the manure is surface applied. Surface in liquefied form. These operations require application is also connected with increases water to flush the barns and transport the in greenhouse gas emissions and in odour- manure to the storage system. related complaints. Nutrients in manure that There are several reasons to be is applied to frozen or snow-covered ground concerned about the amount of water also have a heightened risk of moving from that an intensive hog-operation uses. The the field to surface waters. first relates simply to the issue of water conservation: depending on the water Nutrients source, water used by a hog operation could Nitrogen and phosphorus enter the hog be permanently lost to a region. Beyond this production cycle in the rations that are concern are issues of waste. Highly dilute fed to hogs. This can either be in the form manure is costly to transport and is more of grain or, as is more commonly the case, likely to have an imbalance of nitrogen to pelleted feed (made from grain and other phosphorus (an issue discussed below) and inputs) from feed mills. Federal government the more water per hog that an operation regulations require that commercial uses, the greater the dilution of the manure. feeds contain a minimum level of these In short, excess use of water may be a threat nutrients, which are essential to the healthy to both local and regional water sources development of the hogs. Hogs are not able and may exacerbate manure and nutrient to absorb all the nitrogen and phosphorus handling issues for the operation. in their feed (some of it is in a form that they cannot absorb). The nutrients that 6.1.2 Water quality are not absorbed are excreted. The forms, Concerns over the amounts of water paths, and fates of these nutrients once they used by livestock operations are matched have been excreted are key elements in any by the impacts that outputs from livestock hog-production operation’s impact on the operations can have on surface and environment. groundwater. Most of these impacts can Because nitrogen and phosphorus are come from the nutrients, pathogens, and just as crucial to healthy crop production heavy metals in the manure. There are as they are to the production of healthy numerous routes through which these hogs, hog manure is an effective fertilizer. contaminants can travel: losses at any point Nitrogen improves the vigour, yield, and in the transportation and storage systems, protein levels of a crop, while phosphorus is failure of storage systems, infiltration critical for all growth processes, promoting to groundwater, as well as runoff and root development, early flowering, overland flow from fields on which the efficiency of water use, energy transfer, manure has been applied. In the case of photosynthesis, respiration, cell division, liquefied manure there are economic limits and uniform ripening. Virtually all hog as to the distances that the manure can production operations seek to apply manure

38 Environmental Sustainability and Hog Production in Manitoba to fields so that crops can take advantage of sophisticated; however, for many years these nutrients. Small operations apply the nitrogen was overapplied (Smil 2000). manure regularly throughout the year (and Nitrogen and phosphorus are the two as a result, their operations can lose much most commonly used fertilizers in Manitoba of the fertilizer value, since winter-applied agriculture. In Manitoba, the use of manure can be lost during spring runoff). synthetic fertilizer has risen over the past Approximately ten per cent of operators three decades, with nitrogen going from compost the manure and apply it in solid 25,000 tonnes in 1965 to 265,000 tonnes form, while most large producers retain in 2005 and phosphates going from 25,000 the liquefied manure in a storage system, tonnes in 1965 to 106,000 tonnes in 2005. applying it at specific times of the year. In recent years, there has been a decline There is, however, a limit to the amount of in the sale of these nutrients: from 2003 these nutrients that crops can absorb and to 2006, nitrogen sales declined by 12.3 make use of—that limit is usually referred per cent while phosphorus sales declined to as the crop-removal rate. by 25.7 per cent. Livestock constitutes Most of the world’s nitrogen exists in the the other major source of these nutrients atmosphere and is therefore not available for Manitoba agriculture: Manitoba to plants. Historically, nitrogen in the livestock produce 25,000 tonnes of manure atmosphere has usually become fixed (or phosphorus annually, with 70 per cent made available) for plant and animal life coming from cattle. Despite the fact that through the work of soil microorganisms cattle produce more manure than hogs, the that remove nitrogen from the atmosphere. related nutrient-loss is not as significant as These microorganisms interact with the roots with hogs, since local forage crops recycle of plants to create a form of nitrogen that the majority of cattle manure, which is can become available to plants to take up deposited directly onto pastureland (Lake (Smil 2000). Winnipeg Stewardship Board 2007; Rawluk It was not until the early twentieth and Flaten 2007). century that technology was developed to Nitrogen (whether it be synthetic or synthesize nitrogen (from the atmosphere) in a manure) applied to a field can leave and hydrogen (from natural gas) into in a number of ways: it can return directly nitrogen fertilizer. The creation of synthetic to the atmosphere, it can leach into the fertilizers has led to a significant increase groundwater; it can leave through the in the nitrogen being applied to the soil process of soil erosion; or, having been (Smil 2000). Synthetic phosphorus fertilizer incorporated into a plant, it leaves as part is processed from calcium phosphate rock of the harvested crop (Smil 2000; Steinfeld deposits. et al. 2006). It can also remain in the soil Due to the use of synthesized fertilizers, where it was applied, increasing the nitrogen humans now release as much nitrogen load in the soil. and phosphorus to terrestrial ecosystems Phosphorus is much less mobile and is annually as all natural sources combined. far less likely to be turn into a gas or to Synthetic nitrogen fertilizer not only leach into the soil. It travels from the land dramatically increased the productivity to water usually by erosion or runoff. It is of world agriculture; it created a number also more likely to build up in the soil than of environmental challenges. Over the nitrogen. past century, our understanding of plant Elevated levels of nitrogen in water requirements for nitrogen has become more sources have been associated with methemoglobinemia (blue baby syndrome), miscarriage, and stomach cancer. While phosphorus is not a direct threat to the

39 Manitoba Clean Environment Commission health of humans and animals, increased The final complication is the cost of levels of phosphorus (and nitrogen) can transporting these nutrients. While liquefied change the biological balance in freshwaters. manure is in many respects superior in This is the result of eutrophication, quality to synthetic fertilizers, which are the excessive growth of aquatic plants, what most Manitoba farmers use, it is very particularly algae, in response to elevated costly to transport. The intensification of levels of phosphorus and nitrogen. The livestock production has exacerbated this increase in algae can lead to fish kills (as problem. Manure ceases to be a valuable a result of decreased oxygen levels) and source of nutrients and becomes a waste increases in associated toxins that can disposal issue when the amount of manure harm aquatic life, wildlife, pets, livestock, that an operation produces is too large to be and people. Research has indicated that economically transported the distances that the level of phosphorus in the water is the are required to ensure that it is applied at limiting factor for the development of algae crop-removal rates. blooms (Steinfeld et al. 2006; Lake Winnipeg Stewardship Board 2007). Pathogens Ideally, nutrients should not be applied Pathogens are responsible for 90 per to fields at rates greater than the rate at cent of most food and waterborne illness which crops will remove them from the in humans. Livestock manure can contain soil. Matching application with removal is a range of pathogens (bacteria, parasites, in itself a complex process, requiring an or viruses) that can continue to live for a understanding of the nutrient levels in the period of time in manure applied to soil. manure, the soil characteristics (including They live in the gastro-intestinal tract of such issues as acidity and alkalinity), the animals without affecting the health of rate at which the nutrients will be lost those animals, but can cause illness when to the atmosphere following application, humans consume them in food or water. and the crop requirements. This is further Diseases that jump from animals to humans complicated by the impact that the actual are called zoonoses (Holley et al. 2007). growing season has on crop growth and resultant nutrient uptake. Producers must Heavy metals also address the fact that the ratios of Hog feeds often also include heavy nitrogen to phosphorus in most manures metals (copper and zinc being the most are not the same as most crops’ nitrogen common). While some of these metals occur and phosphorus requirements. A typical naturally in the feed, it is not uncommon crop removal nitrogen-to-phosphorus ratio to add metals, which can serve to promote might be 6-to-1, while a typical manure growth and control disease. Metals that ratio might be between 2-to-1 and 4-to-1 are in excess of the hog’s nutritional (Rawluk and Flaten 2007). As a result of requirements cannot be absorbed by the this imbalance, producers have traditionally animal and are excreted. When the manure applied manure at rates that will meet is applied to the fields these can become their nitrogen requirements. In general this concentrated in the soil. Under certain leads to an application of more phosphorus conditions, excess concentrations of metals than most crops can utilize, leading to an can have negative effects on crop yields increasing phosphorus load in the soil. Until and quality. Heavy metals are also at risk of relatively recently, it was thought that eventually leaching into and contaminating phosphorus was essentially immobile and did ground and surface waters (Steinfeld et al. not leave the soil. Farmers were told that 2006). the build up of phosphorus was, in essence, money in the bank.

40 Environmental Sustainability and Hog Production in Manitoba 6.2 Air of that coming from North American hog Livestock operations can emit well over production (Steinfeld et al. 2006). one hundred different gases that can have Nitrous oxide not only enhances the global and regional impacts. The global issue greenhouse effect, it depletes the ozone most associated with the emissions from layer, thereby increasing radiation risks. hog barns is climate change, while the most Nitrous oxide can be lost to the atmosphere common regional issue relates to odour. during the storage and application of animal manure with the rates being dependent on 6.2.1 Climate change the method of storage and application. Climate change is the result of When natural habitat is turned to changes in the balance of atmospheric cropland there is a decrease in the ability of forces that control such processes as the the land to sequester carbon. To the degree carbon, nitrogen, and oxygen cycles. A that hog production leads to an increase key component in this change has been in cropland (either to produce feed or to the increase in the amount of so-called serve as additional spread fields for manure greenhouse gases (carbon dioxide, methane, application) it increases the carbon dioxide nitrous oxide, and chlorofluorocarbons) in the atmosphere (Steinfeld et al. 2006). present in the atmosphere as a result of human activity. The increased presence 6.2.3 Odour of these gases enhances their greenhouse Hog production facilities can emit effect, contributing to global warming. It is ammonia, volatile organic compounds, predicted that this process will contribute hydrogen sulphide, and other odour- to a variety of undesirable environmental producing gases from animal housing impacts including extinctions, rising sea facilities, manure storage facilities, fields levels, climate extremes, and dramatic on which manure is applied, and from changes to ecosystems. mortality disposal sites. While some of Hogs, like all livestock emit carbon the gases emitted from a hog-production dioxide through their respiratory processes facility can be toxic at high concentrations, and minor amounts of methane through the concentrations that exist outside their digestive processes (ruminant animals the facilities are usually below such such as cows and sheep emit far more), levels (Steinfeld et al. 2006). The odour while their manure emits methane, nitrous sensation from these gases, even below oxides (combinations of nitrogen and toxic concentrations, can however lead to oxygen), ammonia (a compound of nitrogen physiological symptoms and exacerbate and hydrogen), and carbon dioxide. The existing medical conditions (Zhang et al. extent of these emissions depends on the 2007). The World Health Organization (WHO) way the manure is managed. defined health as, “a state of complete The storage of liquefied manure in physical, mental and social well-being earthen manure-storage facilities leads and not merely the absence of disease or to anaerobic decomposition and the infirmity” (WHO 2006, 1)” and the extent release of methane into the atmosphere. to which an individual or group is able, on Methane emission can also take place the one hand, “to identify and to realize when liquefied manure is applied to fields. aspirations, to satisfy needs, and to change The United Nations Food and Agriculture or cope with the environment” (WHO 1986, Organization (FAO) estimates the global 1). Odours from the hog-production industry methane emissions from livestock manure may have an effect on quality of life that management to be 17.52 million tonnes, could result in frustration, annoyance, with 8.38 million tonnes of that being depression and stress, and therefore impact attributed to hogs and 1.65 million tonnes health within the broader definition. Odour

41 Manitoba Clean Environment Commission can constitute a significant potential barrier • Water purification. to the social sustainability of all forms of livestock production • Climate moderation. 6.3 Land • Soil production. • Purification of the air. (Environment 6.3.1 Changes in land use Canada 1995). One of the major impacts of the Livestock Revolution has been the increase in the amount of land put under cultivation The intensification of livestock in order to produce feed for the increase in production can have two very differing livestock. Globally, the increase in cropland impacts on biodiversity. To the degree that between 1950 and 1980 was greater than the it is carried forward without consideration of increase between 1800 and 1950. Much of the environmental impacts of development, this shift has taken place in the developing it can reduce biodiversity. However, to the world, while, in the developed world, the extent that it leads to a more efficient trend has been a reduction in cropland. use of land and resources, it can enhance The global result has been a loss in biodiversity by reducing pressures on natural habitats and the environmental cultivated land (Steinfeld et al. 2006). goods and services those habitats provide. Biodiversity can be threatened by a For example, natural habitats foster and number of trends associated with intensive protect biodiversity, serve as carbon sinks agriculture. These include: (forests sequester carbon), regulate water • Conversion of natural habitat to cycles and reduce the impact of flooding, cropland. and can slow the flow of contaminants to surface waters. These services are, for the • Water eutrophication. most part, not included in any cost-benefit • Impact of antibacterial resistance on calculations of economic development wildlife. (Steinfeld et al. 2006). • The reduction in diversity among 6.4 Flora and fauna livestock breeds. The impacts of the hog industry on flora and fauna are closely inter-related and will • Climate change could lead to changes in be discussed together. Intensive livestock natural habitat and the introduction of production has implications both for the new pathogens and disease, potentially biological diversity of flora and fauna and resulting in an increase in the number for the health of animals and humans. of animals threatened with extinction. 6.4.1 Biological diversity • Transfer of pathogens. Biological diversity (often called As the above list suggests, intensive biodiversity) refers to the diversity of livestock production can, in a number of genetic information, species, and ecosystems ways, have a limiting impact on global bio- and habitats. Biological diversity underlies diversity. many of the ecological goods and services that support life, including: 6.4.2 Health • Conversion of solar energy into The following health issues are related carbohydrates and protein. to hog industry: workplace health issues, animal diseases, and the role that drug • Oxygen production.

42 Environmental Sustainability and Hog Production in Manitoba use can play in increasing antibacterial An outbreak of an animal disease resistance in both humans and animals. such as foot-and-mouth disease or classic swine fever would represent a significant Workplace health and safety threat to the Manitoba hog production Dust (arising from the animal hair, dried industry. In the last decade outbreaks of feces, and feed) and gases (particularly these highly contagious diseases in Taiwan, ammonia, hydrogen sulfide, and methane the United Kingdom, and the Netherlands arising from the decomposition of urine have led to a restructuring of industries and feces) may be acutely hazardous to and widespread public debate over the the health of the people who work in future of the industries. The impact of such hog-production facilities. These problems diseases would be particularly significant are more acute in winter, when there is for Manitoba, given the provincial hog reduced ventilation of the facilities to industry’s dependence on export markets preserve heat. The liquefied manure also for live hogs, since an outbreak would likely can release hydrogen sulphide, which can lead to border closures. The loss of access be fatal in high concentrations. Hog barn to export markets would likely result in workers have died as a result of their being the massive killing of healthy animals and exposed to lethal levels of hydrogen sulfide a sharp drop in the price of slaughter hogs upon entering collection pits beneath (Whiting 2003; Whiting 2006; Whiting n.d). hog-production facilities shortly after the facilities have been drained. Antibiotics There are at least 25 zoonotic infections Antibiotics are administered to livestock (diseases that can be transmitted from for three purposes: 1) to treat disease, 2) animals to humans) that intensive to serve as a prophylactic at times of high livestock operation employees are at risk of risk, for example after weaning or during developing (Cole et al. 2000; Donham and transport, and 3) to promote growth or Thelin 2006). performance. They can increase growth by 1 to 15 per cent. The use of antibiotics has Animal diseases been associated with the development of The stringent levels of bio-security bacteria that are resistant to those drugs. in many intensive livestock operations This can happen either through genetic are a reminder that hogs are vulnerable mutation or the bacteria acquiring resistant to numerous diseases. Raising animals genes from another organism. When in concentrated sites can play a role in animals develop bacteria with resistance to breeding new forms of these diseases. antimicrobials with which they are treated, Increasing attention has been paid in this there are implications for both animals and area to swine influenza. From the 1930s to humans. The potential routes by which drug 1998, North American hogs had been prey resistant bacteria can spread to humans to only one influenza subtype. Since then, are through water, food, or inhalation. there has been a succession of influenza The longer a drug is in use, the greater viruses. Debate exists as to whether the the degree of resistance that develops. concentration of animals enhances the Furthermore, resistance is more frequent development of new influenza strains by in communities where antibiotics are in providing a fertile breeding ground or common use. As resistance grows, infections whether by ensuring hogs do not come are more difficult and expensive to treat. into contact with passing wildfowl the For human medicine, the most serious development of new influenzas is slowed resistance problems are due to the overuse of (Wuethrich 2004). antibiotics in treating humans (Government of Canada 2000).

43 Manitoba Clean Environment Commission As noted at the outset of this chapter, the issues identified above constitute potential barriers to the industry’s environmental sustainability. The next chapter outlines the growth of livestock- related environmental legislation in Manitoba. In the second section of this report, the Commission presents its assessment of the effectiveness of those regulations and producer mitigation measures.

44 7 The growth of the regulation of the hog industry in Manitoba

he hog-production industry is a part the industry. Although Manitoba Agriculture, of the broader livestock sector of the Food and Rural Initiatives (MAFRI) does not TManitoba economy and, with a few act as an environmental regulator, it plays exceptions, there are few regulations that an important role in the development of specifically target hog production. In short, environmental policy and, for that reason, its the history of the regulation of the hog- work is also summarized in this chapter, as production industry is part of the history of are the measures that producers have taken to the regulation of the livestock sector. At the control nutrients. The chapter concludes with same time, it should be noted that over the some comments on regulatory practices in past fifteen years, the hog-production sector other jurisdictions (Box 7.4). has been the most controversial livestock At the outset, it should be noted that the sector in Manitoba and many regulatory federal, provincial and municipal governments changes have been in response to that all play a role in regulating agricultural sector’s growth and development. This chapter operations in Manitoba. outlines the history of provincial government environmental and land-use regulation of

45 Manitoba Clean Environment Commission Federal jurisdiction • The Farm Practices Protection Act Through Agriculture and Agri-Food • The Farm Products Marketing Act Canada and Environment Canada, the federal government as two general responsibilities: • The Livestock and Livestock Products Act 1) Research and development to reduce the • The Municipal Act environmental impacts from agriculture in general. In 1998, Agriculture • The Pesticides and Fertilizers Control Act and Agri-Food Canada announced it would spend $2-million to develop a • The Planning Act national approach to finding effective • The Public Health Act and affordable solutions to the environmental challenges of the hog • The Sustainable Development Act industry by 2001. • The Water Resources Administration Act 2) Compliance with and enforcement of the pollution prevention provisions of • The Water Rights Act the Fisheries Act. Nationally, between 2000 and 2005, Environment Canada • The Workplace Safety and Health Act prosecuted one hog barn for violating the Fisheries Act (Commissioner of Municipal jurisdiction the Environment and Sustainable Municipal governments have the Development 2005). authority to issue building permits and establish zoning provisions within a Provincial jurisdiction framework established by the provincial The Manitoba government is responsible government through The Planning Act and for overall environmental regulation and associated Provincial Land Use Policies land-use planning. The two most significant (PLUPS). pieces of legislation for the regulation of the hog-production in industry are The This regulatory framework has Environment Act (and the Livestock Manure undergone considerable change since the and Mortalities Management Regulation Manitoba government adopted The Clean under that Act) and The Planning Act (and Environment Act, the forerunner to today’s the Provincial Land Use Policies under that Environment Act, in the late 1960s. The Act). Other provincial acts that can have a current Clean Environment Commission bearing on the livestock sector include: (CEC) Investigation is in fact the third major inquiry to be held into the impact • The Animal Care Act of livestock on the environment (although • The Animal Liability Act the first to be specifically restricted to hog production). This section of the chapter • The Contaminated Site Remediation Act outlines the evolution of the regulation of the industry and summarizes the findings • The Dangerous Goods Handling and of the previous investigations held into Transportation Act the livestock industry’s impact on the environment, along with discussions of two • The Endangered Species Act other reports that looked at related issues. • The Environment Act The Chapter is broken into two parts. The first deals with environmental regulation • The Farm Lands Ownership Act

46 Environmental Sustainability and Hog Production in Manitoba and the second deals with land-use decision- • Manure be maintained on the operator’s making. property. 7.1 Environmental regulations • Manure not be discharged to water. 7.1.1 Regulation of the hog industry in • Mortalities be rendered or buried (unless the 1960s and 1970s otherwise approved by the minister). The Clean Environment Act required • There be no manure spills from vehicles that every new and existing industry, carrying livestock. including livestock-production operations, file a proposal or register with the Clean Under this regulation, there was no Environment Commission, and subsequently need for a permit to build a manure-storage receive an order that placed limits on the facility, no inspection of such facilities, discharges to the environment (Manitoba and no restrictions on the application of Government 1978). The Clean Environment Act manure. The regulation was subsequently also provided citizens with the right to take amended to require the registration of environmental complaints to the CEC. some livestock operations, depending Following one such complaint, in 1971 on their size and location. There was no the Commission ordered a Springfield- inspection of operations except in response area hog operation to reduce in size from to complaints. At this point there was, in 2,000 to 800 animals and to eliminate its essence, no provincial approval process system of liquefied manure disposal. The for the development or expansion of provincial Municipal Board upheld the CEC intensive livestock operations. If the rural ruling in February 1972. The Manitoba municipality for which a new or expanding government of the day then amended The development was proposed had a zoning Clean Environment Act to allow the minister bylaw in place, the development might need to overrule CEC decisions. The minister to receive a conditional-use permit from exercised this authority to exempt the the local council. However, many Manitoba Springfield operation from the CEC ruling. municipalities did not have zoning bylaws The residents who had filed the original CEC during this period. complaint then launched a nuisance suit against the operator. In 1975, the Manitoba 1978: CEC investigation into livestock Court of Queen’s Bench, after finding in production their favour, awarded them $10,000 (Wilson In 1978, the Manitoba government 1975). In 1974, while the case was before mandated the Clean Environment the courts, the Manitoba legislature adopted Commission to undertake “an investigation The Nuisance Act, restricting (but not of existing and potential air, soil and water eliminating) the right to sue for nuisance in pollution problems associated with intensive the case of odour. livestock production operations in Manitoba In 1973, the Manitoba government with the objective of development guidelines relieved agricultural operations of their or regulations to provide a workable responsibility to apply for a CEC order solution to such problems” (Manitoba Clean limiting their discharges (Manitoba Environment Commission 1979, 1). In its Government 1978). Instead livestock report, the Commission noted that there had operations over a certain size were required been a change in the intensity of livestock to abide by the Livestock Production production that was likely to continue Operations Regulation, which stipulated into the future. Where in the past “flocks that: and herds were more or less ‘in balance’ with the land and the recycling of wastes

47 Manitoba Clean Environment Commission took place without creating problems,” significant expansion of the hog-production intensive livestock operations were “out industry. In that year, the province brought of balance with nature because of the very in the Livestock Waste Regulation, The Farm large amounts of waste being produced on Practices Protection Act, and released the restricted areas of land” (Manitoba Clean Manitoba’s Pork Industry; Building for the 21st Environment Commission 1979, 3). The Century, the report of the Manitoba Pork two sets of problems identified with this Study Committee. development were: • Risks of pollution to air, soil and water. Livestock Waste Regulation: 1994 In 1994, the government replaced the • The rise of land-use conflicts. Livestock Production Operation Regulation The Commission concluded that while with the Livestock Waste Regulation. The The Clean Environment Act, The Planning Act, new regulation established the following The Municipal Act, and The Public Health additional regulations: Act all provided sufficient authority for • A requirement for a permit to construct dealing with these issues, there was a need earthen manure-storage facilities. for guidelines and regulation to address pollution issues while zoning plans should • Storage siting and construction be used to address land-use issues. standards for earthen manure-storage The Commission recommended that facilities. livestock operations with more than 300 • A requirement that manure storage not animal units be required to register with contaminate the environment. the provincial government (Manitoba Clean Environment Commission 1979, 6). (An • That manure application be on the basis “animal unit’ refers to the number of animals of crop nitrogen requirements. of a particular category of livestock that will excrete 73 kilograms of total nitrogen • Controls on composting of manure. in a 12-month period. Its value is that it allows for cross-species comparisons and • A 100-metre setback from watercourses regulation. See Table 7.1 for full breakdown for field storage and manure storage of Animal Units.) One of its most significant facilities. 50-metre setbacks from wells recommendations was a requirement that and sinkholes. any new or expanding livestock operation • Incineration and composting were exceeding 300 animal units require approved as additional methods for the provincial government approval. disposal of animal mortalities. In large measure, the recommendations of this report were not implemented. In This was the first time the province 1987, the Protection of Water Resources required permits to build storage facilities Regulation (under The Public Health Act) (and permits were not required for steel or prohibited the depositing of manure into or concrete facilities) and the first time that it along water bodies and gave the government attempted to regulate the rate of application the power to order the removal of manure in of manure. It did not at this time require the case of such deposition. manure management plans or inspection of manure-storage facilities. 7.1.2 The 1990s and the expansion of the Manitoba hog industry The first major change in regulatory direction came in 1994, when the provincial government was in the process of directing a

48 Environmental Sustainability and Hog Production in Manitoba

1994: Manitoba’s Pork Industry: Study Committee), dealt primarily with Building for the 21st Century Prospects economic issues, it did discuss sustainable and Challenges development in a chapter titled “Related While the 1994 report, Manitoba’s aspects of the pork industry.” The chapter Pork Industry: Building for the 21st Century did not directly identify or discuss such Prospects and Challenges (produced for the environmental barriers to sustainability Manitoba government by the Manitoba Pork as nutrient loading, climate change, Table 7.1: Calculation of animal units by categories of livestock.

Animal units produced Number of animals to produce Animal Type by one animal one animal unit Dairy Milking Cows, including associated livestock 2.000 0.5 Beef Beef Cows, including associated livestock 1.250 0.8 Backgrounder 0.500 2.0 Summer pasture/ replacement heifers 0.625 1.6 Feeder Cattle 0.769 1.3 Hogs Sows, farrow to finish 1.250 0.8 Sows, farrow to weanling 0.313 3.2 Sows, farrow to nursery 0.250 4.0 Weanlings 0.033 30.0 Growers/finishers 0.143 7.0 Boars (artificial insemination operations) 0.200 5.0 Chickens Broilers 0.0050 200.0 Roasters 0.0100 100.0 Layers 0.0083 120.0 Pullets 0.0033 300.0 Broiler Breeder Pullets 0.0033 300.0 Broiler Breeder Hens 0.0100 100.0 Turkeys Broilers 0.010 100.0 Heavy Toms 0.020 50.0 Heavy Hens 0.010 100.0 Horses Mares, including associated livestock 1.333 0.75 Sheep Ewes, including associated livestock 0.200 5.0 Feeder Lambs 0.063 16.0 Source: Provincial Land Use Policies Regulation.

49 Manitoba Clean Environment Commission biodiversity, antibiotic use, or disease- to file its decisions in court and seek to have related trade issues. It concluded that the the courts enforce them. Livestock Waste Regulation was sufficient to protect groundwater and surface water Livestock Manure and Mortalities from pollution from earthen storage systems Management Regulation: 1998 and that adequate regulation existed for In 1998, the Manitoba government the handling of manure (the regulation did replaced the Livestock Waste Regulation not address above-ground storage facilities). with the Livestock Manure and Mortalities Its essential position on environmental Management Regulation (LMMMR). This new issues were signified by the following two regulation, which applied to all livestock sentences: operations, established the following • “Manitoba’s environmental standards additional requirements: for the development of new hog • Permits for construction of concrete or facilities are the highest of any province steel tanks for manure storage. in Canada.” (Manitoba Pork Study Committee 1994, 62) • Storage facilities be protected to 100- year flood level. • “The bottom line is that hog operations, by law, are not allowed to pollute. • Manure be applied on the basis of crop Regulations are now in place to manage nitrogen requirements and soil texture. the industry effectively.” (Manitoba • Mandatory manure management plans Pork Study Committee 1994, 56) for operations with over 400 animal units. (See Box 7.1 for a description of The Farm Practices Protection Act manure management plans) In 1994, the Manitoba government also proclaimed The Farm Practices Protection • No winter manure application by Act, which maintained the protection from operations with over 400 animal units. nuisance suits that the previous Nuisance Act • Secure and frozen or refrigerated storage had given to persons carrying on agricultural of mortalities. operations. Under The Farm Practices Protection Act, certain nuisance suits could • Mandatory reporting of manure spills. only be launched against an agricultural operation if the operation did not use • A 100-metre setback from watercourses normal farm practices or violated a land- for manure storage facilities and field use control law, The Environment Act and its storage. regulations and orders, or The Public Health The LMMMR contained the first Act and its regulations and orders. Before requirement for manure management plans launching a nuisance suit, a complainant and the first limits on winter application would also have had to have filed a (for operations of a certain size). The complaint with the Farm Practices Protection regulation gave the government the Board. The Board was mandated to attempt authority to require monitoring wells around to resolve the dispute and determine if the manure-storage facilities. Operators were complaint arose from a normal farm practice required to submit test analysis results from or not. If it was not found to be a normal these wells to regional Conservation offices practice, the Board could order the operator where they were entered in a database and to cease or change the practice. The Board’s tracked over time. decisions could be used as evidence in future It was only with the introduction of nuisance cases. The Board also had the right the LMMMR that the government began

50 Environmental Sustainability and Hog Production in Manitoba

Box 7.1 Manure management plans Manure management plans must be The government monitors adherence submitted before February 10 in the case to the LMMMR’s nutrient application of spring application and before July 10 regulation through the use of manure in the case of fall application. The plan management plans (MMPs). All can be amended following that date agricultural operations with 300 or more as long as the appropriate application animal units are supposed to register an and information are provided to the annual MMP. Manitoba Conservation can government. Soil test results must be apply the regulation to an operation with submitted prior to application and there fewer than 300 animal units if there is must be verification of the spread fields reason to believe the operation’s handling required. of manure presents a threat to the Manitoba Conservation can refuse to environment. register a manure management plan if: To follow manure management plans, • The plan does not supply all required producers must provide the nutrient information or is not in the approved content of the manure (actual or form. estimated); test their soil to determine its nutrient content; identify a crop with • The plan has been prepared by an appropriate crop-removal rate; and someone who is prohibited from an application method that will ensure preparing manure management plans. delivery of the appropriate nutrient levels for the chosen time of application. All • Implementation of the plan would be of these factors can be confounded by likely to violate the LMMMR. the weather conditions at the time of • The soil nutrient analysis is based on application. samples that were taken at the wrong Manure management plans must depth or the analysis is not based on include the type of livestock on the acceptable procedures. operation, the number of animal units per species, any increase over the It can also be rejected if it is previous year, the type of manure that submitted after the deadline and the is stored on the operation (liquid, semi- appropriate administration fee is not solid, or solid), the type of storage submitted. Manitoba Conservation staff system, and the volume of manure to be review each manure management plan applied. It must indicate whether the prior to its being registered. manure is to be treated or transferred off Manure management plans can be the farm. prepared by producers or by a person The plan also has to outline the who has either completed an acceptable fields where the manure will be applied, manure management planning course their owner, the size of the fields, the (or has what is viewed to be equivalent soil classification, the proposed crop, training or experience); is either member the phosphorus and nitrogen soil test of the Manitoba Institute of Agrologists results, the phosphorus and nitrogen (or is exempt from registration with the crop-removal rates, the application rate, Institute for the purposes of preparing season, start date, method of application, manure management plans) or is an the amounts of non-manure phosphorus American Society of Agronomy certified and nitrogen being applied, and the crop adviser. name of the applicator.

51 Manitoba Clean Environment Commission requiring inspection of manure-storage traditional issues of manure management, facilities. In 1998, Manitoba Environment odour and land-use decision-making. also established its first Environmental While it called for a number of changes, Livestock program, which was delivered by a Finding Common Ground concluded that the team of approximately eight to nine people industry was, with appropriate regulation, (five fulltime equivalents). sustainable. For example, the report states, “Compared to other jurisdictions in Canada, 7.1.3 Regulating the hog-production Manitoba’s regulations and procedures industry in the 21st century appear to be of an adequate standard, although improvements are certainly The Livestock Stewardship Initiative possible. The overriding issue appears to and Finding Common Ground be the monitoring and enforcing of these In 2000, the Manitoba government standards” (Livestock Stewardship Panel announced the creation of the Livestock 2000, 24). Finding Common Ground presented Stewardship Initiative (LSI). The purpose of approximately 40 recommendations the initiative was to ensure the sustainable under four main headings: 1) The role of development of the livestock industry the provincial government; 2) publicly in the province. In establishing the available information; 3) intensive livestock initiative, the government announced that operation (ILO) and rural development; all constructed manure-storage facilities and 4) siting decisions. The thrust of those would be inspected to ensure protection of recommendations can be summarized as surface and groundwater. Previously, only follows: storage facilities constructed after 1994 were 1) Role of provincial government in inspected. sustainable livestock operation: The Central to the LSI was the appointment majority of the recommendations fell of a Livestock Stewardship Panel consisting under this category. The Panel said of Ed Tyrchniewicz, Nick Carter, and John that its overarching recommendation Whitaker in 2000. At the time of the Panel’s stressed “the need for the commitment appointment, provincial hog production was of staff and financial resources to be 4.8 million annually, up from 3.2 million devoted to two tasks: first, to gain a full in 1996. Of these, 2.2 million (60 per cent understanding of the present situation weanlings) were being shipped to the U.S. It of such operations in the overall was expected that Maple Leaf Foods would milieu of agriculture in the province, add a second shift to its Brandon plant and and secondly, to provide a regulatory Schneider Foods would expand in Winnipeg. framework and a monitoring and It was estimated that to meet the increased enforcement effort in which expansion slaughter capacity would require a $750- can take place without damage to million investment in barns, equipment, Manitoba’s people or environment” breeding stock, and land. (Livestock Stewardship Panel 2000, 10). The Panel held ten public meetings in June 2000 and published its report, Finding 2. Publicly available information: The Common Ground, in December 2000. The Panel reported that it was “surprised report devoted considerably more attention at the lack of assembled information to environmental and social issues than on the distribution of the livestock previous studies. For example, it dealt with industry around the province.” It stated nutrient levels (highlighting the need to that the number or location of hog address phosphorus levels), animal welfare, barns had not been mapped against and antibiotic use, as well as the more broad geographical characteristics on a province-wide basis. There was no

52 Environmental Sustainability and Hog Production in Manitoba

statistical impression of the density the current approach did not favour of large barn development (Livestock large-area planning. For example, the Stewardship Panel 2000, 23). The authors noted that while it is true that Panel favoured the establishment of an Manitoba has a great deal of agricultural information system that would “provide land, the planning process has not been Manitobans with a means for more able to avoid a dramatic concentration accurately tracking the environmental of the industry (Livestock Stewardship effects of present and future livestock Panel 2000, 28). operations (as well as other industrial The Commission concurs with the operations that might impact on water broad thrust of Finding Common Ground. quality)” (Livestock Stewardship Panel That report’s work and recommendations 2000, 49). represent an important step forward in the 3. Role of ILOs in Rural Development: environmental regulation of the livestock While the Panel believed that ILOs sector. The recommendations that the could play an important role in rural Commission will be making in this report development, there should be assistance reflect the Finding Common Ground emphasis available for farmers who do not wish to on the need for a significant provincial role move into more intensive production. in regulating the industry, the importance The Panel recommended what it termed of public information gathering, the need a two-pronged approach in which the for the provincial government to take government developed programs to responsibility for environmental decision enable smaller farmers “to adjust their making, and the significance of large-area farming operations to a level that will regional planning. Because the Commission provide them with an acceptable quality is not examining the social or economic of life” (Livestock Stewardship Panel impacts of the industry, it is not pursuing 2000, 11). the Finding Common Ground concern over the role of ILOs in rural development. 4. Decision process for siting ILOs: The Panel took the position that Growth of the Environmental Livestock municipalities should provide formal Program assessment of new and expanding Even before the Finding Common ILOs to determine if they complied Ground report was released, the provincial with local land use by-laws, while the government began to expand the provincial government should assess Environmental Livestock program, which such proposals for their environmental operated in the Department of Environment impact. The Panel described this as a and then in Conservation. Table 7.2 change from the existing situation in summarizes the increase in resources and which the province relied “on the TRC costs per year. (Technical Review Committee, described in detail below) to advise the municipal council on the compatibility of the project with the environment, and the municipal council alone makes the final decision” (Livestock Stewardship Panel 2000, 37). The panel called for an expanded membership in the TRCs to include the Departments of Health and Labour. Finally, the Panel stressed on a number of occasions that

53 Manitoba Clean Environment Commission

Table 7.2: Increases in staffing and resources of prior to 1998, and molehills constructed the Environmental Livestock Program. prior to 1998. (Registration differs from permitting, in that a facility that Full-time was constructed under the authority Year equivalent Budget of a permit would have been designed 1999-2000 10 $1,035,700 by an engineer to meet Manitoba 2000-2001 5 $1,055,700 Conservation’s standards.) 2001-2003 5 $1,443,700 • Mandatory maintenance or Total 20 decommissioning of storage facilities not Source: Manitoba Conservation. in use. Table 7.3 shows the positions that were • Mandatory reporting of source water added during this process. (the water used in the hog-operation) analyses from operations with 300 or Livestock Manure and Mortalities more animal units. The operator submits Management Regulation Amendments these reports on the quality of the 2004 water that is used to feed their animals In 2004, the province introduced to Manitoba Conservation’s Winnipeg amendments to the Livestock Manure and office where they are entered into a Mortalities Management Regulation that database. required: • Registration of storage facilities without • That the threshold for prohibition permits. This was to be completed by of winter application of manure and 2010 and pertained to earthen storage mandatory submission of manure facilities constructed prior to 1994, management plans be lowered to 300 steel or concrete tanks constructed animal units. (Operators have until 2010

Table 7.3: Positions added to the Environmental Livestock Program.

Year Position Status Locations Environment Engineer (EE2) Fulltime Brandon Environment Officer (EO2) Fulltime Steinbach Hydrologist (EO3) Fulltime Winnipeg Environment Officer (EO2) Fulltime Winkler Environment Officer (EO2) Fulltime Steinbach Environment Officer (EO2) Fulltime Interlake Agricultural Hydrologist (GE3) Term Winnipeg Aquifer Technologist (TE1) Term Winnipeg Agricultural Hydrologist (GE3) Term Winnipeg 1999-2000 Aquifer Technologist (TE1) Term Winnipeg Environment Officer (EO2) Fulltime Brandon Environment Officer (EO3) Fulltime Steinbach Environment Officer (EO2) Fulltime Steinbach Environment Officer (EO2) Fulltime Steinbach 2000-2001 Environment Officer (EO2) Fulltime Winkler Manager Livestock Program (EO5) Fulltime Winnipeg Environmental Engineer (EE3) Fulltime Winnipeg Clerk (CL3) Fulltime Winnipeg Environment Officer (EO2) Fulltime Red River 2001-2002 Environment Officer (EO2) Fulltime Interlake Source: Manitoba Conservation.

54 Environmental Sustainability and Hog Production in Manitoba

to comply with the winter application An Examination of the Environmental prohibition.) Sustainability of the Hog Industry in Manitoba: 2006 • That new and expanding operations be prohibited from winter application, no The 2006 Manitoba Conservation matter what their size. document An Examination of the Environmental Sustainability of the Hog • That commercial applicators must be Industry in Manitoba was issued in response certified and consultants who prepare to the CEC’s 2003 report on the Maple manure management plans must be Leaf Foods application for expansion of its professional agrologists. operation in Brandon. The 2003 report had called on Manitoba Conservation to work • A reduction in the rates of in consultation with other stakeholders to manure application allowable on produce a study of the sustainability of hog environmentally sensitive soils. (Prior to production in the Assiniboine River basin 2004, the regulation was based on soil and to develop sustainability indicators. texture as opposed to soil agricultural In responding to this recommendation, capability.) the provincial government concluded that, rather than looking at the Assiniboine River • Permits prior to the construction of basin, it would undertake a province-wide confined livestock areas of 300 animal survey. units and greater. (These include the The Manitoba Conservation report biotech or hoop structures which provides an overview of many of the had previously been exempt from key issues relating to the hog industry’s permitting.) environmental impact, particularly in • That there be no burning of livestock relation to nutrients and water quality, manure. manure management, cumulative impacts, ground and surface water quality, siting The provincial government also of intensive livestock operations, and established the Manitoba Phosphorus Expert livestock pathogens. The initiatives taken Committee to advise it on steps that needed by the provincial government over the past to be taken to regulate the application of decade as part of the Livestock Stewardship phosphorus in animal manure. Initiative are outlined and responses to the Finding Common Ground recommendations Livestock Manure and Mortalities are briefly summarized. In some cases, the Management Regulation Amendment: explanations are too brief; for example, 2005 the report does not make it clear that the In December 2005, the LMMMR government had chosen not to implement was amended to require that manure the Finding Common Ground recommendations management plans prepared by third parties regarding land-use decision-making. be prepared by professional agrologists The report surveys the various pieces of (P. Ag.) or other trained, competent legislation that govern the livestock sector, professionals. This allowed certified crop and describes key government initiatives and advisers (CCA) as well as professional programs relating to manure management, agrologists to prepare manure management water protection, planning, farm practices, plans. Both the P. Ags and the CCAs have and conservation. It concludes that the to take a course through Assiniboine required land base exists for environmentally Community College. Producers may prepare sustainable application of livestock manure, their own manure management plans. but in some regions of the province further increases in livestock may be inappropriate

55 Manitoba Clean Environment Commission if there is not enough land to handle the Lake Winnipeg Stewardship Board manure (Manitoba Government 2006). Report: 2006 The Commission has found the report to The 2006 report of the Lake Winnipeg be a useful contribution to the Investigation Stewardship Board (LWSB), Reducing that it has been mandated to undertake. Nutrient Loading to Lake Winnipeg and The report does not, however, establish Its Watershed, concluded that excessive the sustainability indicators that were nutrient enrichment from nitrogen and requested in the initial CEC recommendation phosphorus is the leading cause of a long- nor does it investigate the full range of term deterioration in Lake Winnipeg water environmental sustainability issues that flow quality (2006). The report identified both from The Sustainable Development Act. human-activity and natural sources of nutrients. The key human-activity sources Manitoba Phosphorus Expert are: municipal sewage, septic fields, crop Committee: 2006 fertilizers, industrial discharges, livestock The Manitoba government appointed manure, and urban runoff. Natural sources the Manitoba Phosphorus Expert Committee include soil, the atmosphere, and decaying (MPEC) in 2002 to make recommendations plant material. One sign of the impact on managing livestock manure phosphorus. that nutrients have had on the lake is in The MPEC’s report of 2006 recommended the increase in algal blooms. The Board’s restrictions on the rate of manure proposed plan of action included education, phosphorus application, restrictions on the research, setting of long term nutrient goals, fall and winter application of manure, and addressing transboundary issues, developing the establishment of buffer zones in which integrated watershed plans, reducing manure application would be prohibited. cosmetic use of phosphorus-based fertilizers, The report is discussed in greater detail in improving sewage treatment systems and Chapter 9. water use efficiency. The report identified eutrophication as Livestock Manure and Mortalities a key problem facing the lake, noting that, Management Regulation: 2006 when measured by levels of chlorophyll, Amendments Lake Winnipeg appears to be the most In 2006, the LMMMR was amended to eutrophic of the world’s 10 largest lakes. put in place manure phosphorus application- Over the last 30 years, phosphorus loading rate thresholds, further restrictions on of Lake Winnipeg was estimated to have winter and fall application, and setbacks for increased by 10 per cent and nitrogen manure application in relation to surface loading by 14 per cent. water features. These regulations were According to the Stewardship Board, based on the MPEC recommendations and agriculture has a significant impact on the public consultations, and are discussed in water flowing to Lake Winnipeg; of the greater detail in Chapter 9. The threshold for 55-million hectares of the Canadian prairie construction permits for confined livestock farmland in the Lake Winnipeg drainage areas for hogs (largely envirotech hoop basin, half is under crop production. The barns) was lowered from 300 animal units Winnipeg, Red, and Saskatchewan Rivers to 10 animal units. In December 2006, the account for 82 per cent of the mean monthly LMMMR was amended to put the current flow into Lake Winnipeg. In recent years, pause on hog production expansion into flow from the Saskatchewan River (which is place. low in nutrient content) has been declining, while flows from the Red (which is higher in nutrient content) have been increasing. Spring runoff is a major contributor to

56 Environmental Sustainability and Hog Production in Manitoba the flow to the lake: according to one 7.2 Land-use decision-making study, cited by the LWSB, snowmelt runoff Manitoba law has traditionally taken the constitutes 85 per cent of total annual approach that land-use planning is a local runoff from Western Canadian agricultural responsibility. Zoning bylaws, which outline watersheds. activities that can and cannot be undertaken The Red River, which has only 11 in different areas of a municipality, are seen percent of the flow to the Lake Winnipeg, as the appropriate planning instruments. supplies 54 per cent of the phosphorus Historically, zoning bylaws were voluntary and 30 per cent of the nitrogen. The high and many municipalities, particularly smaller fertility of Red River Valley soil and the rural municipalities, did not adopt them. extent of development in the valley are cited Those rural municipalities that did adopt as the reasons behind the high nutrient zoning bylaws usually addressed the issue of content of the flow in the Red River. The the siting of livestock operations by stating dominant form and process of phosphorus that such operations were conditional uses loading appears to be dissolved phosphorus under the bylaw. Under this approach, the during the spring runoff (rates are highest local council had to grant the proponent in April and May). Fifty-one per cent of the of a livestock operation a conditional-use nitrogen and 53 per cent of the phosphorus permit before a livestock operation could be originates in the United States, underscoring established or expanded. As late as 2000, 12 the need to develop a cooperative, rural municipalities had no zoning bylaw to international approach to loading reduction. regulate siting and development of livestock The Lake Winnipeg Stewardship report operations. In isolated cases, municipalities concluded that Manitoba agriculture is the that did not have zoning bylaws were able source of 1,200 tonnes of phosphorus and to regulate the industry under provisions of 5,100 tonnes of nitrogen entering the lake The Municipal Act granting the municipalities each year. This amounts to 15 per cent of authority to pass bylaws dealing with such the total phosphorus load (32 per cent of issues as safety, health, protection and well- Manitoba’s phosphorus contribution) and 5 being of people, and the right to regulate per cent of the total nitrogen load (11 per activities that could give rise to nuisance cent of Manitoba’s nitrogen contribution) complaints. (Lake Winnipeg Stewardship Board 2006, 25- After 1994, the provincial government 26). required that, in cases where the The report called on the Manitoba municipality had a zoning bylaw in place, government to adopt the MPEC the proponent of a livestock operation had recommendations and to support to have all necessary municipal approvals research that will help to further refine (usually a conditional-use permit if the soil-phosphorus thresholds for varying operation was above a specified size) Manitoba soil types and landscapes. It before it would grant the proponent a also recommended the development of a manure-storage-facility permit. It was terrestrial nutrient budget for Manitoba that only after both permits were received that considers all agricultural nutrient sources construction of the project could commence. and nutrient exports. It recommended (In the early part of the current decade, a that the proponents of new and expanding government legal opinion concluded that livestock operations be required to the department had to issue a permit as long demonstrate that they have sufficient land as the applicant met the requirements of available to balance phosphorus application the LMMMR. However, according to Manitoba rates with removal rates over the long-term. Conservation, no permits were issued unless the necessary municipal approvals had been received by the proponent.)

57 Manitoba Clean Environment Commission The role that municipalities play in the corporate entities that are liable for their approval of intensive livestock operations own actions. became increasingly controversial over the past two decades. As early as 1994, in its 7.2.1 The Planning Act report, the Manitoba Pork Study Committee The provincial Planning Act sets out noted: the framework for Manitoba zoning law, including the legal requirements that must Rural Municipal Councils have found be met to adopt a bylaw. It is administered themselves in the centre of these by The Department of Intergovernmental disputes, without adequate information Affairs. with which to make an informed decision The Planning Act allows municipalities or an appropriate process to resolve to establish development plans that would basic disagreements. This situation work within a set of provincial land-use places undue pressure on all parties and policies (PLUPs). The intent has been to must not continue because it fails to develop future-oriented development plans adequately address and balance both the that would be supplemented by zoning environmental risks and the potential bylaws. Development plans were essentially economic benefits of hog projects for municipal bylaws: the plans that were all Manitobans. (Manitoba Pork Study initially adopted usually did not deal with Committee 1994, 56) intensive livestock operations in detail, simply stating that large-scale livestock In some cases, industry proponents operations would be viewed as requiring argued that the conditional-use system conditional-use permits. The Planning Act was being abused by councillors, who were also created the possibility of municipalities being stampeded by small, but vocal, groups joining together to establish planning of hog industry opponents. They believed districts. PLUPs were first established in that councils put unrealistic restrictions on 1980 as Planning Act regulations intended some developments (in terms of distances to serve as guidelines in the development of from other properties, requirements to cover municipal development plans. manure-storage facilities, and requirements In response to the controversies that to inject or incorporate manure) and, in arose at the municipal level over the other cases, rejected proposals that met all approval of hog-production facilities, the appropriate environmental and land-use The Planning Act underwent a number of regulations. Others believed that municipal changes. councillors had fallen under the sway of proponents and the provincial government, 7.2.2 The Planning Act amendments: which they viewed as an active promoter of 2000 the hog industry, and as a result, failed to In 2000, The Planning Act was amended enforce municipal regulations and allowed to make Technical Review Committee (TRC) development to take place in the face of reports mandatory prior to the consideration local opposition. As a rule, the provincial of an application for a conditional-use government does not initiate any form of permit for a livestock operations of 400 legal action against municipalities that or more animal units (this applied only in do not abide by The Planning Act. Instead, those municipalities that had adopted a the provincial policy has been to draw the zoning bylaw). The Manitoba government fact to the municipality’s attention that its had established regional Technical Review action is not in accordance with the Act Committees in 1994 to evaluate new farm and could leave the municipality open to a operations in light of the Farm Practices legal challenge. The municipalities are legal Guidelines. Made up of representatives

58 Environmental Sustainability and Hog Production in Manitoba from Agriculture, Rural Development, provincial approval, a development plan Natural Resources, and Environment, the must be submitted to the province. committee’s role was to “evaluate a project Before the municipality or planning or projects on behalf of hog farmers and district can adopt the plan, it must rural municipalities to help maintain receive the approval of the Minister of good environmental practices for farming Intergovernmental Affairs. The minister operations” (Manitoba Pork Study Committee can refer objections to the plan to the 1994, 56). According to the discussion Municipal Board, which must then hold paper prepared for the 2000 Livestock a hearing on the plan. The Minister Stewardship Initiative consultation, TRCs can chose to either accept the bylaw, were expected to provide local governments reject the bylaw, or approve it subject with evaluations of proposals for new or to the municipality or planning district expanding operations and to assist in making any alterations required by the exchange of information between the the minister or complying with any proponent, local government and rural condition imposed by the minister. The residents (Manitoba Government 2000a). municipality or planning district can The 2000 amendments to The Planning either choose to adopt the plan (along Act also required that residents who lived with any alterations or conditions within two kilometres of a proposed ILO be required by the minister) or pass a given notice of the local conditional-use motion not to proceed with the plan). hearing (previously notice had been required After consulting with a municipality or for residents who lived within 100 metres planning district the minister may order of the proposal). Again, the provision only it to adopt a development plan. If the applied in those municipalities that had municipality fails to comply with such adopted zoning bylaws. an order the minister may prepare a development plan. Before imposing this 7.2.3 The Planning Act: 2006 plan on the municipality or planning Conflicts over approvals of livestock district, the minister may seek the operations (mainly hog-production advice of the Municipal Board on the operations) continued into the new century. plan. Amendments to The Planning Act were proposed but subsequently withdrawn The adoption of a new development plan in 2004. In 2005 a new Planning Act was must be preceded by public hearings. adopted, coming into force in 2006. It The development plan must be generally sought to provide the industry with greater consistent with provincial land use predictability, while allowing municipalities policies. Once approved, it replaces the to retain their ability to approve or reject PLUPs for that municipality or planning proposals. The 2006 Planning Act contained district and all departments and a number of important conditions specific to agencies rely on the development plan livestock operations and intensive livestock policies to guide their recommendations operations in particular. Under the Act, and decisions. municipalities and planning districts are required to: The minister has the authority to grant exemptions to the deadline • Adopt a development plan and a for adopting development plans. The zoning bylaw by January 1, 2008. Commission has been informed that The plan can only be adopted after the such exemptions have been granted in municipality or planning district holds response to requests from a number of a public hearing on the proposed plan. municipalities and planning districts. While a zoning bylaw does not require

59 Manitoba Clean Environment Commission

• Incorporate a livestock operation • Make livestock operations of over 300 policy into new or existing animal units mandatory conditional- development plans by January 1, use operations. If the municipality 2008. The livestock operations policy does not have a zoning bylaw, the must set out: provincial government will require that (i) Areas where the expansion or the municipality hold a conditional-use development of livestock operations hearing into the project. The province of any size may be allowed. will not provide manure-storage permits (ii) Areas where the expansion or to operations of over 300 animal units development of livestock operations if they do not have conditional-use involving a specified maximum permits. number of animal units may be • Provide notice to residents within allowed. three kilometres of a proposed (iii) Areas where the expansion or livestock operation involving 300 development of livestock operations or more animal units of a public will not be allowed. hearing into the proposal. There is It must also set out the general also a requirement that the meeting be standards to be followed respecting advertised in the newspaper and that the siting and setback of livestock the property be posted. operations. The plan must provide In the case of operations of 300 or more reasons for the restrictions or animal units, the initiating step for the prohibitions on livestock operations. conditional-use permitting process under Furthermore, the reasons must draw on The Planning Act is the proponent’s request the following factors: to the municipality or planning district for (a) soils; a permit. The municipality forwards that (b) the size of a livestock operation, request to the provincial government, which, based on the number of animal units in turn, refers the request to the appropriate in the operation; TRC. (c) proximity to significant surface water The Planning Act requires that TRC bodies, such as lakes, rivers and reports be provided to the appropriate wetlands; planning district board, municipal council (d) flood risk areas identified by the or planning commission, and that the province; appropriate planning authority make the (e) groundwater vulnerability areas report available to the public. The legislation identified by the province; does not outline the TRC’s range of inquiry (f) proximity to areas designated in the or method of operation. There are three development plan as regional TRCs, with representation from (i) urban centres or settlement centres, Manitoba Agriculture, Food and Rural (ii) rural residential or seasonal Initiatives (MAFRI), Intergovernmental residential areas, and Affairs, Water Stewardship, and Manitoba (iii) parks or recreational areas; and Conservation. They also have the authority (g) existing land uses in the area. to include representatives from other • Adopt siting and setback regulations departments with interest in the project. in their zoning bylaw that were no The director of the MAFRI Land Use Branch less stringent than the siting and (or designate) chairs the TRCs. The reports setback standards established by are expected to look at cumulative impacts regulation in the Manitoba Provincial in terms of assimilative capacity of the Land Use Policy for agriculture. land base of the proposed facility, and

60 Environmental Sustainability and Hog Production in Manitoba neighbouring livestock operations (within which, the Act states must be “relevant and a two-kilometer radius) to utilize livestock reasonable”: manure on a sustainable basis as a crop (a) measures to ensure conformity with the nutrient (Manitoba Government 2000b). applicable provisions of the development While the Manitoba government seeks to plan by-law, the zoning by-law and any complete the TRC report within 60 days of secondary plan by-law; receiving all the necessary information, in 2006, the average completion period was 104 (b) measures to implement recommendations days. made by the Technical Review The council is required to give public Committee; notice of a public hearing that is to be held at least 30 days after it receives the TRC (c) one or both of the following measures report. A representative of the TRC (not intended to reduce odours from the all TRC members) must be present at the livestock operation: public meeting where the TRC report and the (i) requiring covers on manure-storage proposal are discussed. The council can then facilities, decide to reject, approve, or approve the (ii) requiring shelterbelts to be proposal with conditions. More specifically, established; the Act states the Council can only approve (d) requiring the owner of the affected if: property to enter into a development (i) the Technical Review Committee has agreement. determined, based on the available The Act also states that the only restrictions information, that the proposed that a conditional-use permit can place operation will not create a risk to on an operation “respecting the storage, health, safety or the environment, or application, transport or use of manure,” that any risk can be minimized through relate to the covering of storage facilities the use of appropriate practices, and requiring shelterbelts. measures and safeguards, and The conditional-use permit is valid for (ii) the proposed operation 12 months, although it may be extended for an additional 12 months. During the A) will be compatible with the general eight-year period from 1998 to 2005, 14 nature of the surrounding area, per cent of the projects that were proposed B) will not be detrimental to the health and reviewed by TRCs were not approved or general welfare of people living by councils. Because TRC reviews have only or working in the surrounding area, been required for assessments of operations or negatively affect other properties above a set size (initially 400 animal units, or potential development in the now 300 animal units), this does not surrounding area, and account for all the projects that came before C) is generally consistent with municipal councils during that period. the applicable provisions of the development plan by-law, the zoning 7.3 The role of Manitoba by-law and any secondary plan by- law. Agriculture, Food and Rural The implication of section (i) is that Initiatives the Council cannot approve in the face of a A key element in the mandate of TRC finding that the operation constitutes Manitoba Agriculture, Food, and Rural a risk to health, safety, or the environment. Initiatives (MAFRI) is to assist in the If it approves the project, the council can economic development of the agriculture only impose the following conditions, sector. In that sense, its focus is on

61 Manitoba Clean Environment Commission promotion, education, and outreach as delivery of the Environmental Farm Plan opposed to the regulation of agricultural (EFP) program by reviewing and editing producers. Agronomic and environmental the EFP workbook, developing a workshop issues are however closely intertwined, and format, and reviewing and recommending a number of MAFRI initiatives have a clear appropriate beneficial management practices and important environmental focus. The (BMPs). It also assisted in the development clearest example of this focus is the Agri- of the Farm Stewardship Association of Environment Knowledge Centre. Manitoba review process for the EFP. (See Box 7.2 for more on the Environmental Farm 7.3.1 The Agri-Environment Knowledge Program.) Centre Centre staff also coordinated the 2007 The Agri-Environment Knowledge Center edition of the Farm Practices Guidelines for provides services addressing agricultural Pig Producers, a volume that had not been environmental issues. It assists in the

Box 7.2 Environmental Farm Plan environmental issues on their farm and Program techniques that can be used to manage The Environmental Farm Plan Program those issues. Based on this training, the was introduced in Manitoba as part farmers develop Environmental Farm of the federal-provincial Agricultural plans that are reviewed by FSAM. Once Policy Framework. It is accompanied by the plan has been successfully reviewed, the Canada-Manitoba Farm Stewardship producers are eligible for assistance from Program (CMFSP), which provides the Canada-Manitoba Farm Stewardship financial and technical support to Program to implement environmental producers to implement environmentally practices identified in their plans. beneficial actions identified in their Producers can receive between 30 to 50 Environmental Farm Plans. When it was per cent of the cost of implementing the initially announced in 2005, the federal plan up to a maximum of $50,000. The government committed $30-million to the plans include funding for such programs program in Manitoba, while the provincial as: government committed itself to more • Manure management. than $10.4-million of in-kind support. The Manitoba support was for workshops • Relocation of livestock confinement and technical support to producers in facilities. the development and implementation of Environmental Farm Plans. The program, • Product and waste management. currently set to run to March 2008, • Water well management. should be renewed into the future. The Farm Stewardship Association • Riparian protection. of Manitoba (FSAM), a non-profit organization, assists in the delivery of • Integrated pest management. the program in partnership with the • Shelterbelt development. federal and provincial government. Farmers who participate in the • Biodiversity enhancements. program attend a series of workshops coordinated by the FSAM at which • Grazing strategies. they receive training in identifying

62 Environmental Sustainability and Hog Production in Manitoba updated since 1998. The Guide is a valuable • Reduce the impacts of odours. set of guidelines for hog production that helps local governments evaluate hog- • Improve water management. production proposals and assists producers • Ensure the management of the entire in operating in a way that makes the agricultural landscapes including such maximum use of manure while mitigating broader riparian areas and cropped odour and environmental impacts. They uplands. also participated in the Technical Review Committees. In response to the development • Protect ecological goods and services. of the new restrictions on phosphorus application, staff were engaged in a variety 7.3.2 Covering New Ground (The of extension education activities, including Agricultural Sustainability Initiative) presentations to agronomists (particularly The Agri-Environment Knowledge Centre through the Crop Diagnostic School), also administers the provincial Covering reprogramming the Manure Application New Ground program (also known as The Rate Calculator, revising the Farm Agricultural Sustainability Initiative). Practices guidelines, revising the Manitoba Covering New Ground is a provincial Environmental Farm Plan, and contributing government program that provides funding to course manual development for training and technical help to producer groups manure-management planners and custom- and commodity organizations that are manure applicators. The Manure Application developing pilot projects that address Rate Calculator is a piece of computer environmental agriculture issues. Established software that assists producers in developing in 1998, it has provided funding to over manure management plans. 1,000 projects. In relation to the hog The Centre staff are also involved in industry, it has sponsored projects that developing strategies to address ways of controlling phosphorus loss • Adapt to climate change. through BMPs. Agri-Environment Knowledge Centre • Reduce off-farm energy requirements. staff are also involved in soil assessment and analysis work for a range of agronomic and • Rehabilitate soils. environmental purposes in the province’s integrated watershed planning that is led by

Box 7.3 Environmental goods and private land. It received funding from services the federal and provincial government, In 2005, a pilot Alternative Land Use the Delta Waterfowl Foundation, the Services (ALUS) program was established Manitoba Rural Adaptation Council, in the RM of Blanshard. The project was and the RM of Blanshard. The program developed by the Keystone Agricultural provides farmers and landowners with Producers and is administered by a financial incentive to maintain and the Manitoba Agricultural Services enhance wetlands, ecologically sensitive Corporation. The program provides lands, riparian areas and natural areas. producers with a small payment for The payments vary on the service being providing ecological services that provided. Approximately 20,000 acres provide environmental benefits to are enrolled in the ALUS program to the public-at-large from resources on date (Grier et al. 2007).

63 Manitoba Clean Environment Commission the Manitoba Water Stewardship. Through cannot digest phytic acid and, as a result, its Livestock Stewardship Initiative, it the hogs excrete this phosphorus. In barley, recently helped sponsor the trial use of a 75 per cent of the phosphorus is in the form centrifugal manure separator in Manitoba. of phytate, which means the animal simply The Agri-Environment Knowledge Centre also passes most of the phosphorus through its helped sponsor the Manitoba Alternative system. In order to ensure that hogs receive Land Use Initiative, started in 2005 and sufficient phosphorus, it has been necessary intended to promote the delivery of for producers to add dicalcium phosphate Environmental Goods and Services. (See Box to the feed. Pound for pound this is one 7.3). of the most expensive feed additives. Over MAFRI’s Livestock Knowledge Centre the past decade phytase, an enzyme that also provides producers with advice in allows hogs to digest phytic acid has been regards to production-related nutrient marketed to the hog industry. To the degree issues such as feed composition. Engineers that operators use this additive, they are on staff with the department also assist able to increase the amount of phytic acid with questions regarding manure-storage phosphorus the hog absorbs. This allows facilities. them to reduce the amount of dicalcium phosphate added to the feed and to reduce 7.4 Controlling nutrients the total amount of phosphorus in the Producers can and are taking a feed, thus reducing the total amount of number of steps to improve their control phosphorus that is excreted. over nutrients. In so doing, they are The Commission has been told that becoming more efficient and increasing many producers are now adding phytase to the environmental sustainability of their their feed mix. However, the environmental operation. This section is meant to bring benefit of adding phytase will not be felt together issues that are addressed separately unless producers make corresponding in this report and identify some of the reductions in the addition of dicalcium measures that producers are taking. There phosphorus. Most producers did not start are several important points at which adding phytase until 2002. The Manitoba producers can exercise considerable control Pork Council told the Commission that over nutrient loss. These are: phytase is added to the diets of 60 per cent • Feed composition. of all Manitoba hogs. Producers are not able to take full • Feeding strategies. advantage of the benefits of phytase due to federal regulations that mandate a specific • Manure storage. level of phosphorus in animal feed. The Canadian Food Inspection Agency (CFIA), • Manure application. under the authority of the federal Feeds Act • Beneficial practices evaluates and approves ingredients for use in livestock feeds. The Feeds Regulation under Feed composition this Act sets out, on a species-by-species basis, minimum and maximum levels of A key step in this management process nutrient in feeds. The regulation, which has involves managing the nutrients that are not been amended since 1983, was developed brought onto the farm. Phosphorus levels well before producers began adding phytase in hog manure are elevated because most of to hog rations. The amount of phosphorus the phosphorus present in the grains (and in that it requires to be added to hog feed is the grain components of pelleted feed) is in based on the assumption that most of the the form of phytic acid. Monogastric animals phosphorus will not be available to the hog.

64 Environmental Sustainability and Hog Production in Manitoba

While the current regulation provides feed the more commonly used barley straw covers companies and producers with some room to that are blown on the surface of the manure- maneuver, the full environmental benefits storage facility. The Manitoba Pork Council of phytase will not be achieved until the told the Commission that 15 to 20 per cent federal government revises this regulation. of the manure produced in Manitoba is The Commission encourages the provincial protected by covers. Elite Swine told the government to work with the federal Commission that it had 20 sites with straw government to remove barriers to further covers and 13 sites with synthetic covers. feed efficiencies by modifying the Feeds The Puratone Company told the Commission Regulation to reflect industry and research it was working with a company called AgCert developments of the past quarter century. that would cover manure-storage facilities The Commission also urges feed companies as part of an agreement to sell certified to develop more efficient feed mixes (more emission credits on an international phytase, less dicalcium phosphate). exchange. A related issue has arisen in In Manitoba, operators store manure Saskatchewan where researchers have in both one-and two-cell manure-storage developed a strain of barley that is lower in facilities. With the two-cell system, the phytate and higher in available phosphorus. manure goes into a primary cell, in which The researchers have not been able to the solid fraction settles out from the liquid. register the barley as a feed because of a The liquid is then moved into the secondary conflict with the CFIA over the registration cell. The manure that is applied from the category. While the Commission has not secondary cell will have a lower phosphorus investigated this case in full (in which the content and not need to be agitated before CFIA wishes to register the barley as a novel being pumped out of the cell. strain, while the academic researchers who developed it believe this is an inappropriate Manure application designation that will also serve as a barrier There are two important steps in to its use), it encourages the provincial applying manure appropriately. The first government to work with the federal involves determining the appropriate government to ensure that environmentally amount of manure that should be applied; friendly feeds are available to producers. the second involves the method of application. Feeding strategies To determine the appropriate rate at Hogs require different levels of nutrients which manure is to be applied, the producer depending on their age and their stage must develop a manure management plan as in development. Many producers have described in Box 7.1. This process involves adopted split-sex feeding and phase feeding both manure and soil testing, both of which strategies. These strategies can reduce the give producers valuable information in nutrient content of manure. The Commission controlling the movement of nutrients. was told that many producers employ The injection or incorporation of manure both of these feeding practices. The large dramatically reduces nutrient loss to the producers indicated that these practices atmosphere and reduces odour concerns. were common on their farms. Injection or incorporation is used on over 80 per cent of the land on which the Manure storage predominant hog producers apply liquid Nitrogen can be lost to the atmosphere manure. The Manitoba Pork Council told the when manure is stored in uncovered manure- Commission that between 70 to 80 per cent storage facilities. Synthetic covers are most of Manitoba manure is injected. effective, but are much more expensive than

65 Manitoba Clean Environment Commission The timing of manure application also for hog manure. It is thought that it could has an impact on controlling nutrients. serve to produce energy, reduce odour, The Manitoba Pork Council stated that the and concentrate phosphorus so that it can industry is moving towards the ending of all be economically transported. It remains winter spreading. However, most application an expensive technology, which is not takes place in the fall as opposed the spring, easily adapted in an economic fashion to which is the optimal time in terms of Manitoba’s climate, particularly in light of controlling nutrient loss. the low energy costs in the province. Aside from the above methods, a variety The hog industry has contributed of cropping, tillage, and soil management to improvements in the environmental methods can also be used to address the operation of the industry in a number issue of manure movement from fields to of ways. For example, the Canadian Pork ground and surface water. However, the most Council developed the Canadian Code of effective measures are those that can assure Practice for Environmentally Sound Hog the appropriate amounts of nutrients are production. It stresses environmentally applied in the correct ratios. sound manure management with attention to long-term manure storage, incorporation Separation and treatment of manure below the soil surface prevention All of the above methods might be of water contamination, odour control, termed soft methods for nutrient control. manure application rates, and adequate If producers find that, after investigating land for application (Holley et al. 2007). or employing these methods they are still It also notes that Manitoba Conservation not able to bring the nutrient budget and Manitoba Agriculture, Food and Rural into balance, it may be necessary to move Initiatives (MAFRI) staff continue to play to some form of manure separation or an important role in their work with treatment. While the technologies are not producers to help the industry develop more widely used in Canada, they are employed sustainable nutrient management practices. in other jurisdictions. However, issues of Finally, the Commission supports climate and geographic concentration could the Lake Winnipeg Stewardship Board play a role in limiting the applicability of recommendation that the federal and some of these technologies. The Manitoba provincial governments support research into government has, in recent, years been beneficial management practices and fund assisting producers in exploring the the implementation of effective practices. potential of centrifugal separation and anaerobic digestion. With use of the centrifuge, the solids and liquids in manure are separated, the phosphorus largely settles out in the solid portion, while the nitrogen remains in the liquid portion. The nitrogen and phosphorus ratio in the liquid portion more closely approximates the crop- removal rates for both nutrients, making it possible to apply liquid to fields in an economic manner. The solid portion is easily composted and economically transported and serves as a valuable phosphorus fertilizer. The anaerobic digestion of manure has been seen as a potential treatment process

66 Environmental Sustainability and Hog Production in Manitoba

Box 7.4 Other jurisdictions only a portion of any jurisdiction’s As a part of its terms of reference, response to environmental issues: issues the Commission was instructed to “take that are not dealt with in regulation into account the efforts underway may, for example, be adequately dealt in other jurisdictions to manage hog with by policy. Nor is the stringency of production in a sustainable manner.” a regulation necessarily an appropriate The Commission has addressed this measure of its effectiveness. There also requirement in a number of ways. As a remains the question of compliance and part of its work, the Commission reviewed enforcement: if regulations do not have studies on global trends in environmental legitimacy in the community and an regulation of the industry from a global adequate enforcement regime, they will perspective (Oenema 2004; Steinfeld et have little impact. An assessment as to al. 2006). These studies confirmed for which jurisdiction has the best regulatory the Commission that The Sustainable approach can only be the result of detailed Development Act and its principles and comparative studies of all the components guidelines provided an appropriate set of of a regulatory regime. criteria for assessing the environmental Comparison of agricultural regulations sustainability of the hog production is further clouded by the very nature of industry. agricultural activity. Agriculture takes The Commission also commissioned place in a diverse, complex, highly a range of research papers, each variable, and unpredictable environment. investigating a different aspect of the Most command-and-control regulatory hog-production industry. The authors of approaches work best when dealing with these papers were requested to include uniform conditions. The best regulatory discussions of how other jurisdictions measures will be developed to meet handle environmental issues. These papers the specific conditions of a specific were posted on the Commission website jurisdiction—which means that they may and made available to the public during or may not be the best approaches for the hearing process. The Commission Manitoba. encourages policy makers and members of Through its work the Commission has the broader public to review these reports. identified the following regulatory tools: In the following chapters of this • Seasons when application of manure report, the Commission assesses the and fertilizer should be restricted or barriers to the sustainability of hog banned. production in Manitoba and the associated provincial government environmental • Regulations on how manure is to be policies. In reaching its conclusions and applied (for example, requirements for formulating its recommendations, the injection or incorporation, bans on Commission took into consideration surface application). the approaches developed in various jurisdictions. It has, however, not adopted • Setbacks for odour control. a checklist and scorecard approach to • Setback to protect water quality. this issue, nor is it prepared to make comparative judgments as to whether • Licensing of water withdrawal. or not Manitoba has or does not have the strongest (or weakest) regulations. • Permitting requirements for manure- Legislation and regulation constitute storage facilities.

67 Manitoba Clean Environment Commission

• Manure management plans with • Incentive programs to encourage the required soil and manure tests. adoption of environmentally friendly practices. • Water -quality monitoring. This list is not exhaustive, but does • Phosphorus and nitrogen application give a sense of the range of issues that limits based on crop uptake. jurisdictions are addressing. In some areas, Manitoba has had regulations in place • Emission regulations and controls (for for over a decade, in other instances, example, covers for manure-storage provincial regulation is more recent, and facilities). in other cases, there is need for new initiatives. In many cases, it would appear • Training and licensing requirements. that the Manitoba regulations are amongst • Requirement for municipal approval the strongest, particularly if one restricts prior to construction of intensive the comparison to North America. In the livestock operations. end, the Commission is less interested in determining which jurisdiction has the • Requirements for animal space. strongest paper regulation, but whether Manitoba has the appropriate regulations. • Requirements for manure processing. On a concluding note, a number of • Identification of ecologically sensitive observations can be made about the and vulnerable zones. history of the regulation of livestock in developed countries that may provide • Public input into decision making and some insight into the tensions that public access to information. agricultural environmental regulation gives rise to. • Manure storage capacity requirements. • Most governments have been hesitant • Prohibitions on the discharge of to extend environmental regulation to manure. agriculture, since the countryside has traditionally been seen as a repository • Farm budgeting of nutrients. of virtue and health. When problems began to be identified in the 1970s, • Regulations on feed content. reluctance to embrace environmental • Regulation on the disposal of policies that could lead to a reduction mortalities. in livestock numbers or concentration led many governments (particularly • Regional watershed based decision- those with highly developed livestock making and planning. sectors) to place their faith in technological innovation. • Animal disease surveillance programs (particularly those diseases that can • Environmental impacts of agricultural spread to humans). practices can be very slow to develop—and the impacts can • Antibiotic resistance surveillance develop away from the farm site, and programs. even away from the region in which agricultural operations are located. By the time the impacts are identified, the agricultural practices that

68 Environmental Sustainability and Hog Production in Manitoba

contributed to them (and it is usually • Once policies are put in place, it is the case that agriculture is not the likely that there will be continued only contributor and not the sole adjustments. cause) have become standard practice, and may well be seen as economically • In many jurisdictions, there have been necessary for the survival of the conflicts not only between farmers sector. Environmental mitigation and environmentalists over the measures, while expensive, may be relationship between the environment of limited impact, particularly in the and agriculture, but also been within short term, further undermining the government between departments legitimacy of such measures. charged with promoting agriculture and protecting the environment • There exists a tension between what (Bureau d’audiences publiques sur are described as command-and-control l’environnement. 2004; Grier et al. models (that depend on regulation 2007; Oenema and Berentsen 2005; and enforcement) versus incentive Steinfeld et al. 2006). or stimulation models (that depend more on reward and education). It should be noted that these are not necessarily mutually exclusive models. If they are not properly integrated however, farmers as a class can feel criminalized and appropriate practices may not be adopted.

• Agriculture is an extremely expensive sector of the economy to regulate. Furthermore, many aspects of agricultural operations are very difficult to regulate with precision.

• Environmental policy usually includes a commitment to the polluter pay principle, with the goal of having many environmental costs that are currently externalities, internalized by producers. While in some cases, the process of internalization will lead to the adoption of increasingly efficient practices that will reduce the regulatory cost, there is no doubt that environmental regulations have increased the cost of raising livestock. At the same time, governments have been faced with increased costs in both regulating the industry and in assisting producers in adopting new techniques.

69 Manitoba Clean Environment Commission

70 8 Public Input

ublic participation is a key element locations.) While presenters were requested to in the ongoing work of the Clean limit their presentations to fifteen minutes, PEnvironment Commission. Because of individuals and organizations were able to the broad range of issues associated with make longer presentations if they had made the environmental sustainability of the prior arrangement with the Commission. All hog-production industry in Manitoba, the of the presentations were transcribed and Commission held two separate sets of public were posted on the Commission’s website meetings. At the first set, held in January 2007 (www.cecmanitoba.ca). The Commission also in three locations in agro-Manitoba, members received 50 written submissions, which were of the public were invited to provide input as also posted on the Commission website. In to what they believed should be included in addition, the Commission engaged a researcher the scope of the Commission Investigation. to meet with individuals who wished to discuss The second set was held in March and April the industry in a less public forum. A report 2007. Over a period of 17 days, 188 people based on these interviews has been prepared made presentations in 14 locations. (See and was made available on the Commission appendices for a list of presenters and website (Irwin 2007).

71 Manitoba Clean Environment Commission The following is a summary of key dealt with on a regional or site-specific points made during the meetings, in the basis, integrating good economic farm submissions, and in the private sessions, management. arranged by the subject headings that the Others raised questions about the Commission identified through the scoping sources of nutrients in Manitoba waterways. process. They indicated that some studies suggested the sources of these nutrients could be 8.1 Nutrient management natural processes or crop production rather There were three essential, and than livestock, and noted that there will be conflicting, opinions presented on the little producer participation in government- proposed phosphorus regulation. The promoted beneficial management practices first was that the regulation is sufficient programs unless producers believe the to address the issue of phosphorus practices are relevant to local conditions. accumulation in soils from the application These presenters often called for further of livestock manure and that most research into nutrient transport mechanisms producers would be able to conform to the from soil to water. regulations. In parts of Western Manitoba, The Commission heard considerable the Commission was told that soil is so evidence on the measures that producers deficient in phosphorus that the regulation take to control the nutrient content of hog will present little if any burden to producers. manure. These include feed formulations A second opinion was that the regulation (decreasing the amount of nutrients in the constitutes a significant financial burden, ration and utilizing amino acids), the use particularly for small producers. It was of phytase (an enzyme that increases the suggested that in some areas it could double animal’s ability to access phosphate in feed), the cost of pumping manure to fields. phase feeding (changing the feed mix for Those who took this position argued for hogs depending on their age), and split- financial assistance for producers who must sex feeding (feeding male and female pigs incur additional costs to comply with the different feed mixes). Producers stated the regulation. In southeastern Manitoba, it province could assist them by encouraging was stated that some producers are going federal regulators to lower the required to have to clear additional land to meet phosphate level in hog rations in light of the regulatory requirements. Many small the use of phytase and to allow for the feed- producers will also be obliged to build grain registration of grains that are low in manure-storage facilities when winter phytate (the use of these grains would lead application is banned in the Red River Valley to a decrease in the amount of phosphorus Special Management Area. The third position the animal excrete). was that the regulation, which under certain Beyond these points of view, there circumstances allows phosphorus to be were concerns that the government has applied at rates that exceed crop-removal introduced so many regulations, and rates, would do nothing to reduce nutrient changed them with such frequency, that it is loading and amounts to a license to pollute. not possible to examine their effectiveness. These critics often held that thresholds should be based on the ability of crops Critics of the industry regularly to use nutrients, should consider residual suggested that there was not enough nutrients applied in previous years, and monitoring and inspecting of the hog- should not be based on the holding capacity production industry. This criticism was of the soil. raised in relation to numerous issues, Several presenters stressed that including nutrient management, soil testing, the phosphorus surplus issue should be manure application, and storage-system

72 Environmental Sustainability and Hog Production in Manitoba operation. It was also argued that the fines field for professional applicators was three for those who were prosecuted for violations kilometres. Numerous producers employ a of the regulations were not a sufficient variety of technologies to separate the solids deterrent. It should be noted that industry and liquids in manure, reduce odour, and representatives also called for increased create valuable dry manure. enforcement and auditing of manure Other presenters noted that in the past management plans. livestock producers had applied manure as Concerns that regulations were not a soil amendment to meet agronomic needs. enforced were balanced by views that took Now it was being applied to meet the waste the position that regulation threatened management needs of industrial hog barns at the viability of many small operations. The rates that exceeded crop uptake. There was Commission was told that it should consider also concern that in some locations liquefied ways of reaching goals through incentives manure is being spread on marginal land and rather than regulation. In the case of cattle pasture without being incorporated regulations intended to protect the general into the soil. Where there are conduits from environment, it was suggested that the the surface to the aquifer, this represents a public at large bear a portion of the costs potential environmental threat. generated by these regulations. It was generally recognized that the winter application of manure on fields is 8.2 Manure management not environmentally desirable and many The key concern with manure presenters called on the Commission to management was whether manure, which recommend a complete ban on the practice. might contain pathogens, growth hormones, Small producers indicated that such a ban antibiotics, chemical disinfectants, heavy would likely force them to cease production. metals, and excessive amounts of nitrogen For this reason, there were recommendations and phosphorus, either leaks or escapes from that any ban on winter application be barns and storage facilities or is spread in a accompanied by financial assistance that way that threatens the environment. would allow producers to develop alternate It was stressed that manure contains storage systems. many important nutrients not found in Presenters also suggested that bans be synthetic fertilizers. Furthermore, the placed on the application of manure in the majority of pigs on farms at any one time fall, in ecologically sensitive areas, and on are weanlings, who produce very little the same plot of land on a regular basis. manure. It was estimated that the hog Injection and incorporation of manure industry only produces enough manure to into the soil was described as the most cover 15 per cent of total provincial cropland effective method of controlling odours using the phosphorus regulations. Properly and limiting nutrient loss. For this reason, handled, it was not a waste, but an asset. there were calls that it be made mandatory. Manure is usually applied by Representatives of larger producers stated professional applicators according to manure that they currently injected wherever management plans, often completed by possible, the exception being on forage professional agrologists, that must be fields. Applicators urged the provincial registered with the provincial government. government to implement its commitment to The applicators make use of global license all applicators. positioning technology, auto-steer, and Several people suggested that the flow meters. Changes in technology have dry manure systems associated with meant that the pumping distance had hoop-barn production systems were grown steadily over the past three years and more environmentally friendly than the the average distance from storage unit to confinement system, although others

73 Manitoba Clean Environment Commission disputed this. Finishing hogs on straw requested they be provided with an appeal (hoop-barn production) was said to be from the decisions of rural municipalities, advantageous in terms of capital investment while municipalities insisted that their and operating costs, lower odour production, decisions remain final. production flexibility, ventilation, and Concerns were also expressed over animal welfare. It was acknowledged that the quality of decision-making by rural the straw-based system could not serve as municipalities. It was suggested that the basis for large-scale production. councillors lacked the background to make Critics of the earthen manure-storage complex technical decisions, that they had systems called on the Commission to ban conflicts of interest, bowed too easily to them outright: if this were not done it was public pressure, and failed to enforce those suggested that liners and covers be made restrictions that they placed on those hog- mandatory and that the storage systems not production operations that they did approve. be sited over aquifers. It was also suggested It was often stated that a proposal for a that the provincial government review the hog barn created divisions in a community, minimum capacity of storage facilities to although it was suggested that some of allow for adverse weather and moisture these divisions dissipated once a barn was in conditions. Producers regularly made the operation. point that they, their families, and their Producers stated that in the past animals all depend on local groundwater municipalities that opposed hog production sources, and therefore they are careful to had placed prohibitive conditions on make sure that the manure-storage systems proposed developments. A number of do not contaminate groundwater. They municipalities were critical of The Planning also pointed to the requirement that they Act, which restricts their ability to place regularly test groundwater around the conditions on new and expanding barns. earthen manure-storage systems. If new It was felt that the freedom to develop manure-storage regulations were to be appropriate local restrictions had allowed introduced, producers state the province them to control the odour issue. Without the should assist producers in meeting these right to set such rules, they might have no new costs. option but to reject new proposals. Several concerns were raised over the 8.3 Land-use planning and setback distances that have been developed approval for separating developments from residences, Opinions relating to land-use planning waterways, and protected areas. It was and the approval process for hog-production said that these were in need of updating facilities were wide ranging. However, the in light of new research into public health, most prevalent tension revolved around and did not provide adequate protection the hog industry’s desire for consistent, from odour. It was argued that, during the province-wide rules that would make siting process, it is up to existing residents investment decisions more predictable, to demonstrate that the livestock operation and the desire of local communities to will present an odour issue for residents. retain the right to approve or reject local Some wished to see this onus reversed. developments. While industry representatives Producers also called on the provincial wished to see hog-production operations government and rural municipalities to declared permitted uses in areas zoned for ensure that rural residential development livestock, municipalities sought the right does not encroach upon land designated for to continue to declare intensive livestock livestock production. operations conditional uses, even in areas The Technical Review Committees (TRC) zoned for livestock. Similarly, producers were the subject of considerable discussion.

74 Environmental Sustainability and Hog Production in Manitoba

Many acknowledged that the work of the drinking water standards are the result TRCs has improved considerably over the of substandard construction, location, or years and some stated that they do an maintenance. What was needed, it was effective job of providing municipalities with suggested, was a more aggressive policy to the information needed to make informed cap local wells. As noted above, producers decisions. Even those who were satisfied stressed that they would be among the with the advice given by the TRCs stated first affected by contaminated water that they lack sufficient resources and, as a and therefore take appropriate measures result, there were significant delays in the to protect groundwater. Finally, several TRC report. suggested that there were cases where the Critics of the TRC process felt the siting of municipality wastewater lagoons committees tended to be advocates of the was not as strictly regulated as the siting of hog industry. They faulted them for not livestock manure-storage facilities. always making onsite inspections, relying Others pointed to the number of too heavily on the proponent’s information, manure-storage facility failures and spills and not having all members of the that have taken place at certain hog committee present at the council meeting operations and said that, in many cases, where the committee report is discussed. operators ignore the rules regarding There was concern that TRC members application, at times even dumping liquefied were being placed in conflict of interest manure into ditches. Furthermore, it was situations, since they can be expected to stated that storage facilities had been assist proponents in developing proposals constructed over aquifers and on sandy soils and then participate in the assessment of or too close to surface water bodies. In the those proposals. There were also concerns opinion of these individuals, the expansion that TRC recommendations were not of the hog industry has been coincident acted upon, even though the project was with an increase in water and air-quality approved. problems. Some felt that the TRC process provided the public with the illusion that an 8.5 Groundwater supply environmental review was being undertaken The Commission heard sharply of each proposed hog barn. Some suggested polarized views on the hog industry’s that the only effective solution was impact on groundwater supply. Industry to subject proposals to a full-fledged representatives stated that in comparison environmental assessment. Such a review to either aquifer recharge rates or human would assess intensive hog production use, the hog industry makes limited use of on the basis of industrial as opposed to Manitoba’s groundwater supply. Since many agricultural regulation. farmers are obliged to store the liquefied manure and later apply it at considerable 8.4 Groundwater quality cost, they have a strong incentive to control The key groundwater quality issue water use by employing more efficient related to the hog-production industry drinking systems, better wash-down arises from concerns that contaminants equipment, and leak detection alarms. Other from barns, manure-storage facilities, presenters stated that it does not make or spread fields can reach groundwater any ecological sense to use water to create supplies. Industry members pointed out liquefied manure. It was also stated that if that there has yet to be a link between the global warming increases the stress on local hog industry and contaminated water in water supplies, the sustainability of the hog Manitoba. The Commission was told that industry would be thrown into question. 90 per cent of rural wells that fail to meet It was suggested that the Manitoba

75 Manitoba Clean Environment Commission government not allow hog producers to self- 8.7 Soil quality monitor water use. As a stand-alone issue, there was little On a broader scale, some called for discussion of soil quality. It was noted that a comprehensive water usage policy to the new phosphorus regulation could lead measure actual groundwater withdrawal some hog producers to put more marginal rates, aquifer levels, and water quality on an land into production to provide them with ongoing basis. more spread fields. Furthermore, hog- industry regulation has led to a significant 8.6 Surface water quality increase in provincial soil testing. Again, One point that was made repeatedly by this was an area where some presenters producers was that the hog industry, which argued there needed to be increased they stated represented only 1 to 1.5 per independent auditing and verification. cent of the phosphorus loading of Lake Winnipeg, was being unfairly singled out as 8.8 Odour being responsible for phosphorus loading of Producers presented several different rivers and lakes. Industry, municipalities, perspectives on the issue of the odour and the City of Winnipeg in particular, created by hog production. Many suggested all played significant roles in discharging that noise, dust, and odour are facts of nutrients to surface waters and needed to rural life and the needs of agriculture are improve their environmental performance. more important than any idealistic view of Why, presenters wanted to know, did the country life. There was also a suggestion government not place a moratorium on the that the major source of complaint was expansion of other activities that made people who had moved from the city to the a greater contribution to the phosphorus country. Other producers did acknowledge loading of the environment? Several that in the early years of intensive pointed to local studies that suggested the livestock operation—when manure was application of manure to local fields was not not injected and storage systems were not leading to increases of phosphorus in local covered—odour was a severe problem. Many waterways. producers also spoke of how they warned Other presenters noted that drainage neighbours when they would be applying projects over the years had eliminated manure and attempted to time manure many of the marshes and wetlands that had application to avoid interfering with special served as natural filters for nutrient-rich events that neighbours were planning. By water flows. They called for a reinvigoration covering storage systems, injecting and of river and stream basin authorities and incorporating manure when it is applied to conservation districts through the province. fields, separating solids from liquids, and It was also suggested that vegetated buffer growing shelterbelts around storage systems, zones should be mandatory around barns producers have attempted to minimize and spread fields. odour. Producers also stated that, for many Critics of the industry argued that small operators, a requirement to cover the hog industry’s contribution to the manure-storage facilities with synthetic phosphorus load in Manitoba waters was covers would be economically ruinous. much greater than 1.5 per cent. Concerns Despite the introduction of these were also expressed about the threat measures in many operations, the presented to the earthen manure-storage Commission heard from people who said that facilities during flood periods. They their daily lives and possibly their health suggested that dykes be required to protect had been seriously impacted by odour and the storage systems against flood, overflow, emissions from hog-production facilities. liner failure, and rupture. They spoke of being prisoners in their own

76 Environmental Sustainability and Hog Production in Manitoba homes, of being hit by a wall of stench when production over the past three decades has they stepped outside, and of asthmatic and not been accompanied by commensurate other respiratory problems related to hog modernization of regulations to protect the barn exposure. The efficacy of shelterbelts health of the public. was questioned, since by the time the Health professionals raised concerns shelterbelts are fully grown, the barns about the occupational hazards arising may well be ready to be decommissioned. from working in hog barns, pointing to Some farmers spoke of having to work with both a wide range of respiratory concerns burning eyes when they are in the field and concerns over the possibility of hog to at the same time that manure is being human-disease transmission. While hog barn applied in a neighbouring field. Finally, the workers are not covered by either workers Commission was reminded that airborne compensation or employment standards emission issues might extend beyond odour. legislation, they are covered by workplace The emissions from hog operations include health and safety legislation. Producers also hydrogen sulfide and ammonia, toxins that stated that when Farm Practices Guidelines are regulated when they are emitted by are followed, the risk to public health from other industries. manure handling or manure storage is low. Complaints about odour can be taken to The question of whether antibiotics the Farm Practices Protection Board. Some use could lead to situations where certain presenters felt that many people are not antibiotics would no longer be effective in aware of the Board’s existence and wondered treating humans was raised. Producers stated whether it was able to respond quickly to that there has been an ongoing decrease in any citizen complaints. Others called on the the use of antibiotics and pointed out there provincial government to develop a process is a requirement that hogs be antibiotic free to determine unacceptable levels of odour, when they go to slaughter. Some presenters and put in place a policy and enforcement suggested that straw-based operations spend mechanisms to address the issue. more on feed but less on antibiotics. Several presenters stressed that the best Questions were also raised as to whether way to avoid odour problems is to ensure Manitoba was prepared for the implications that the appropriate decisions are made that a disease-related border closing could during the land-use planning process. Others have on an export-based highly productive called for a return to the legal regime under livestock industry. which there were no restrictions on the right to sue for nuisance in response to odour 8.10 Climate change complaints. The relationship between climate change and the hog-production industry was not 8.9 Disease transmission extensively addressed during the meetings. Industry representatives stressed Producers recognized that the industry the fact that they had introduced a wide contributes in a small way to climate change range of biosecurity measures to protect through the emission of greenhouse gases, human and animal health. Many illnesses but claimed these effects are mitigated to long associated with the hog industry a large extent through the displacement are no longer present, as a result, and of artificial fertilizers. Others said that if Manitoba pork enjoys a strong international climate change results in a reduction of the reputation for quality. The segregation of local water supply, the impact on the hog swine from pets and animals had reduced industry could be significant. Producers the threat to human health from disease stated that if greenhouse-gas issues required and parasites to negligible levels. Critics a reduction in the number of pigs being argued that the industrialization of livestock

77 Manitoba Clean Environment Commission raised in Manitoba, producers would have to Social and economic issues were be compensated. discussed extensively. The case was made that the hog industry was making a 8.11 Environmental liability significant and positive contribution to the The issue of environmental liability provincial economy and to the local rural was not touched on in detail. While some communities. Furthermore, it stimulated presenters were worried that the public a range of spinoff industries including could be left with a significant clean-up bill construction and transport. The industry should there be a major contamination of also represented an important local market water or soil or in the event of a cost-related for Manitoba grains in light of the end of industry collapse, others stated that there the Crow Benefit. currently exists appropriate legislation to From a different perspective, it was deal with any environmental liabilities that suggested that a full-cost accounting, that occur in the future. While some suggested included all forms of subsidization, might that the industry be required to pay into a lead to a conclusion that the industry is fund that would cover any such liability, the neither economically nor environmentally industry argued that environmental liability sustainable. According to this argument, issues are, in essence, site specific. large-scale hog operations encourage rural depopulation since small producers 8.12 Other jurisdictions find it very difficult to compete with the Reference was made through the larger producers. The fact that most large meetings to issues in other jurisdictions. producers are corporately owned was cited From the producers’ perspective, the point as an indication that intensive livestock that was regularly made was that the operations could serve as a drain on rural Manitoba hog industry was one of the communities, since profits would not be most heavily regulated hog industries in retained locally. An associated argument the world. Other presenters pointed to the was that meat production itself is a less European models of hog production that sustainable form of agriculture than have alternative approaches to sow housing production for vegetarian diets. One measure and strict budgeting of nutrients. Reference that was urged on the Commission to was also made to the impact of various reassert the interests of the small producer swine-related diseases in other jurisdictions. was to recommend a return to the single- The future of the North Carolina moratorium desk sales system that had been established on manure-storage facilities was also in the 1970s. highlighted. A recurring issue was that of lack of access to information about intensive 8.13 Other issues livestock operation applications, Technical Many other issues were brought before Review Committee reports, water quality, the Commission. Perhaps the most obvious and manure management. It was argued is the future of the current prohibition on that without such information, members industry expansion: some wished to see of the public are not able to make an it lifted as soon as possible, while others effective contribution to the debate on the suggested it be extended indefinitely. environmental sustainability of the hog Similarly, some thought there was little industry. need for change to the current regulatory Animal welfare issues were also and approval regime, while others believed raised. Concerns were expressed about the that there was need for significant change if treatment of animals both in gestation pens the current restrictions on expansion of the and transportation. It was also recommended industry were to be lifted. that there be fire codes for hog barns.

78 Environmental Sustainability and Hog Production in Manitoba

Programs such as the Environmental Farm Plan were cited as examples of policies that provide meaningful assistance to farmers who wish to adopt more environmentally friendly practices. There were also calls to assist farmers in adopting organic farming practices. The Commission was also urged to determine if the Manitoba government has a legal duty to consult with Aboriginal people on hog-industry development in cases where the industry could affect Aboriginal rights to fish or trap or might impinge on Aboriginal water rights.

As noted, not all the issues raised before the Commission fell under its mandate. However, the Commission has paid close attention to the presenters and to the written submissions that it received. They played an important role in identifying issues and providing the Commission with guidance. The input received during the meetings played an important role in shaping the analysis and recommendations presented in the second section of this report.

79 Manitoba Clean Environment Commission

80 9 Water quality

Introduction to Section Two issue, and makes recommendations where hapter 6 of this report identified the appropriate. barriers that lie between intensive As was done in Chapter 6, this section Chog production and environmental will deal with the issues under the headings sustainability. In some cases, due to local provided in the definition of the environment conditions, the expected environmental in The Sustainable Development Act: water, air, complications do not materialize. In other land, flora and fauna. This Chapter will deal cases, preventative or mitigating measures with water-related issues: the first section may be in place to allow the industry to of the chapter deals with water quality, maintain environmental sustainability. Finally, the second section will deal with water there may be requirements for enhanced supply. Chapter 10 deals with air-related measures to ensure the environmental issues. Chapter 11 deals with issues related sustainability of the industry. This section to land, flora, and fauna—reflecting the of the report surveys the current evidence interconnectedness of these issues. Chapter 12 regarding the various barriers, outlines deals with the decision-making process, while government measures to regulate the

81 Manitoba Clean Environment Commission Chapter 13 addresses information and Manitoba Conservation’s Environmental research issues. Livestock Program. That audit deals with issues directly related to the subject of this 9.1 Water quality chapter and is discussed in Box 9.1. In the The greatest environmental threat to body of this chapter, the Commission also water quality from intensive hog production makes reference to a number of the audit comes from the liquefied manure that is findings as they relate to issues identified by stored in either earthen manure-storage the Commission. facilities or above-ground manure-storage facilities and then applied to fields as 9.1.1 Environmental risk related to fertilizer. The manure contains nutrients, field application pathogens, and heavy metals that can The Commission was told by either leach into groundwater or run off representatives of large-scale hog-production into surface waters with potential negative firms and manure-application firms that, environmental and health impacts. The in the case of large operations, most of most important point of concern for the the liquefied manure that they apply is Commission is the risk of environmental either injected or incorporated shortly damage that can arise if these potential after application. According to the 2006 contaminates in the manure escape from farm census, 65 per cent of all Manitoba the field into the surrounding environment. hog farms inject manure (Brewin et al. Such movement can arise either from 2007). Manure is usually applied without loss from fields on which manure has injection or incorporation on forage fields been applied or if the storage system and pastures. Smaller operations use a range fails to provide the appropriate level of of application techniques, many of which environmental protection. The Commission do not involve injection or incorporation. shall treat these two risks separately, Smaller operations (currently those under starting with the risks related to field 400 animal units) can also apply manure on application of manure and moving to risks a year round basis. related to the integrity of manure-storage Table 9.1 is based on the 2006 Census systems. of Agriculture’s data regarding the 768 In November 2007, as the Commission Manitoba farms that are identified as was completing its work, the Manitoba predominant hog operations (which means Auditor General released an audit of

Table 9.1: Manure application methods for predominant hog farms in Manitoba.

Application Method Incorporated or injected (in the case of liquid Manure Type manure) Not incorporated Applied by irrigation Farms reporting composted manure 82 19 Hectares 4,218 362 n/a Farms reporting solid manure 84 33 Hectares 3,160 870 n/a Farms reporting liquid manure 336 135 17 Hectares 41,945 7,188 1,154 Source: Statistics Canada, 2007.

82 Environmental Sustainability and Hog Production in Manitoba

Box 9.1: Audit of the Department of of required contingency plans for potential Conservation’s Management of the livestock manure emergencies; and lack of Environmental Livestock Program control over winter application. In November 2007, the Manitoba The Commission has reviewed a Auditor General released an Audit of the number of these issues as part of its Department of Conservation’s Management current Investigation. It is satisfied of the Environmental Livestock Program. that the current manure management The audit looked at the performance of the regulation gives the government the program from March 1998 to June 2005. needed authority to control manure The audit had four specific goals: application on operations with over 300 animal units and that the regulation • To determine whether the Livestock allows the government to require an Manure and Mortalities Management appropriate storage capacity. Through the Regulation was generally comparable new Nutrient Management Regulation, to legislation in other jurisdictions the government is developing a regulatory • To determine whether Conservation framework to address non-manure nutrient had adequate processes in place application to fields. The Commission to ensure operators of livestock notes that Conservation has indicated that operations comply with the key it is reviewing the LMMMR to determine provisions of the Regulation. if further changes regarding contingency plans are required. Changes to the LMMMR • To determine whether Conservation will place further restrictions on winter used information available to further application of manure. its efforts to protect surface and The Auditor General identified areas groundwater from contamination. where Conservation could strengthen a series of operational issues. These • To determine whether Conservation included: was sufficiently consulting with the Departments of Agriculture, • The permitting process for manure- Food and Rural Initiatives, Health, storage facilities. Intergovernmental Affairs, and Water • The construction monitoring process. Stewardship, as well as municipalities, on common issues related to water • Post-construction monitoring process. quality. • The registering of non-permitted On the first point, the adequacy of manure-storage facilities. manure application regulation, the Auditor General concluded that Manitoba laws were • The monitoring of manure application. “more comprehensive and proactive than in some other provinces” (Auditor General • The fuller utilization of the available of Manitoba 2007, 1). The report identified information system. deficiencies in the control of manure by A wide range of issues was identified operations with multiple species; the lack under these headings. Some, while serious, of requirements for a specific number of appear to have been isolated events, while days of storage; controls to address issues others represent more immediate concerns. raised by the application of both manure In most cases, Conservation indicated that and synthetic fertilizers on fields; the lack it would be taking measures to address the

83 Manitoba Clean Environment Commission

issues raised by the Auditor General. The recommendations, Conservation gave Commission also examined a number of identical responses, namely that the this issues and makes recommendations recommendations included many of the on them throughout this report. tasks that had been assigned to this In two of its responses to the Auditor Investigation. While this Investigation General, Manitoba Conservation made has involved an assessment of the work reference to the ongoing work of this that Conservation has undertaken, Investigation. It was recommended that its focus has been more on the risks Conservation conduct an analysis of the and regulatory framework than on livestock program’s data to aid in the Conservation’s strategic direction. development of a strategic direction for Similarly, while the Commission has the program and that it consult with consulted extensively with the public, other departments and municipalities these consultations do not preclude to identify issues of common interest Conservation developing ongoing in sustaining the agricultural economy relations with other departments while at the same time protecting the and municipalities to address agro- environment. In response to both these environmental issues. that hogs account for more than 50 per Since 1994, Manitoba’s Livestock Manure cent of receipts). It outlines the manure- and Mortalities Management Regulation application methods of these operators, (LMMMR) has required that this manure showing that liquefied manure is applied be applied at rates that do not exceed to a total of 50,286 hectares of land and the nitrogen crop-removal rate. As noted that 83 per cent of that manure is either in Chapter 6, the ratio of phosphorus to incorporated or injected. nitrogen in manure differs from the ratio As noted above, liquefied manure between the phosphorus and nitrogen can contain nutrients, pathogens, and removal rates for most crops. When manure heavy metals that represent potential is applied at the nitrogen removal rate, environmental concerns. The next phosphorus is usually being applied at rates sections of this report review these issues that are higher than the phosphorus crop- individually. removal rate, potentially leading to build up of phosphorus in soils and phosphorus Nutrients losses (mainly through surface runoff). Estimates of the amount of nitrogen To apply manure at the phosphorus crop- and phosphorus produced annually by removal rate would require between 500,000 Manitoba’s hog industry vary between and 700,000 hectares (10-15 per cent 22,500 and 24,000 tonnes for nitrogen and of Manitoba’s agricultural land base). In 5,000 and 7,000 tonnes for phosphorus. short, under the provisions of the LMMMR’s This is equivalent to 8-9 per cent and 12- nitrogen regulation, manure phosphorus was 17 per cent of the synthetic nitrogen and being applied at between four to six times phosphorus fertilizer that is being added the provincial average phosphorus crop- to Manitoba soils. It is also equivalent to removal rate (Rawluk and Flaten 2007). This 8-9 per cent and 11-15 per cent of the is an environmentally unsustainable rate of phosphorus and nitrogen that Manitoba application. crops remove. Currently, hog manure is If the nutrient management issue were applied to 120,000 hectares or 2.5 per cent simply a matter of getting access to more of Manitoba’s agricultural croplands (Rawluk land, the sustainability issue could be and Flaten 2007). easily resolved. Manitoba has 4.7 million

84 Environmental Sustainability and Hog Production in Manitoba hectares of cropland and each year synthetic Source factors fertilizer is applied to 3.5 million of these Application rates hectares (73 per cent of Manitoba cropland). The MPEC’s recommendation for Unfortunately, the issue is complicated by source factors established three different the intensive and regionalized nature of thresholds and set maximum application Manitoba hog production and the cost of rates for each threshold. The thresholds transporting liquefied manure. Liquefied were based on soil tests that measure the hog manure is less concentrated compared presence of phosphorus that is available to commercial fertilizer, and comparatively to plants in the soil in parts per million more expensive to transport. As a result, it (ppm). These results are usually referred is currently uneconomical to apply all the to as Soil Test P or Soil Test Phosphorus. hog manure produced in Manitoba at the The soil test commonly used in Manitoba is phosphorus crop-removal rate. referred to as the Olsen Test. Table 9.2 sets The provincial government has been out the MPEC’s recommended phosphorus aware of the growing phosphorus surplus thresholds and application rates. (The on lands fertilized with hog manure and MPEC recommendations actually refer to the economic barriers to addressing this the application of P205, a phosphorus issue since at least the beginning of formulation. For simplicity, this report will the decade. In response to the issue, it refer to it as phosphorus). appointed a committee to review the issue As can be seen from the table, at and, in 2006, it acted on that committee’s levels of less than 60 ppm, the only limit recommendations by amending the LMMMR on the application of phosphorus is the to regulate the application of phosphorus. current nitrogen regulation. Given that the nitrogen and phosphorus ratios in manure The Manitoba Phosphorus Expert Committee are variable (depending on such factors as recommendations feed composition, age of the animals, and In 2002 the Minister of Conservation degree of agitation of the manure prior to appointed the Manitoba Phosphorus application) and that different crops have Expert Committee (MPEC) to recommend different uptake rates for both nitrogen appropriate measures for regulating and phosphorus, it is not possible to phosphorus application. The MPEC’s 2006 make a specific statement as to what the report called for measures that addressed phosphorus application rate is when one both source and transport factors associated is applying manure at the nitrogen rate. with phosphorus in manure. However, the generally accepted range,

Table 9.2: Manitoba Phosphorus Expert Committee recommended phosphorus application rates.

Soil Test Phosphorus Threshold Phosphorus application rate Less than 60 ppm phosphorus Apply phosphorus on the basis of crop nitrate nitrogen requirements. Between 60 and 119 ppm Apply phosphorus up to two times the crop-removal rate of phosphorus phosphorus Between 120 and 179 ppm Apply phosphorus up to one times the crop-removal rate of phosphorus phosphorus 180 ppm or greater phosphorus No phosphorus application without written consent of the Director (Manitoba Conservation) Source: Manitoba Phosphorus Expert Committee

85 Manitoba Clean Environment Commission depending on the crop, is between three Nutrient transport factors and five times the phosphorus crop-removal In recommending measures that rate. Under the MPEC recommendation, when reduced transport-related risks, the MPEC the phosphorus level in the soil reaches recommended the establishment of two sorts 60 ppm, application must be restricted to of special management areas that would twice the phosphorus crop-removal rate. be subject to additional regulation. These At 120 ppm, the operator is required to zones were made up of either land that is apply at no more than the phosphorus crop- subject to regular inundation or land located removal rate, while at levels of 180 ppm immediately adjacent to surface water. or higher, no phosphorus is to be applied In the zones subject to inundation, the without specific authorization. In essence, restrictions deal with timing of application; the recommendation allows phosphorus while in the zones located near water, the to build up in the soil until it reaches 120 restrictions called for buffer zones between ppm. At that level, operators must balance application and the surface water. application with crop removal. At levels Inundation zones above 180 ppm, they must reduce the levels Winter and fall application of manure by allowing crops to remove the residual present potential environmental problems. phosphorus. Winter-applied manure presents the greatest The MPEC concluded that, due to the risk since it is applied on top of frozen dilute nature of liquefied manure, it could ground and, come spring, is at great risk of be very difficult and expensive for manure being washed off the land in the snowmelt application equipment to apply manure runoff. Nutrients in manure applied in the at the one-time phosphorus removal fall are also at risk of being lost to the rate (particularly for crops with very environment through a variety of routes, low phosphorus crop-removal rates). To including spring runoff rather than being accommodate producers in these situations, taken up by crops. The 2001 Statistics it recommended that operators restricted Canada Agriculture Census showed that 66 to a one-times crop-removal rate be allowed per cent of operations in Manitoba with to apply at up to five times the phosphorus livestock applied manure in the fall. This crop-removal rate on the condition they not fall application represented 54 per cent apply manure to the field in an equivalent of the manure applied. Spring application number of following years. For example, accounted for 21 per cent of the manure if the operator applied at the four-times applied and summer applications accounted phosphorus crop-removal rate, the operator for 22 per cent. Only three per cent of the would be prohibited from applying manure manure produced in Manitoba was reported phosphorus for the next four years. to have been winter applied. This winter- Underlying the MPEC recommendations applied manure came from 11 per cent of was a belief that many Manitoba soils could operations (Rawluk and Flaten 2007). benefit, from an agronomic perspective, At the time of the MPEC report, new if modest increases in phosphorus in soil and expanding operations and existing levels were allowed in the short-term with operations with more than 400 animal units a future goal of establishing a balance were prohibited from applying manure between application and removal. In setting between November 10 and April 10 of the the thresholds, the MPEC was attempting to following year. In 2004, the government balance environmental protection and the had announced that existing operations economic survival of the food-production with between 300 and 400 animal units industry (Manitoba Phosphorus Expert had until 2010 to cease winter application Committee 2006). of manure. The MPEC recommended that winter application be banned completely in

86 Environmental Sustainability and Hog Production in Manitoba the Red River Valley or flood plains of other the MPEC recommended a series of buffer designated rivers. zones between Manitoba watercourses and At the time of the MPEC report, all fields on which manure was being applied. operations could apply manure to croplands Lakes were given the greatest degree of from April 10 to November 10 without protection because they are at the greatest restriction on the manner of application risk of eutrophication, while rivers, creeks, (unless they were restricted by the and large drains received the second highest municipality). The MPEC recommended that, level of protection since they are more likely in the Red River Valley or flood plains of to contain water on a year round basis, and other designated rivers, manure applied therefore, are more likely to be transporting to tilled soils in the fall should either be large quantities of nutrients. injected or incorporated within 48 hours. Table 9.3 outlines the buffer zone Buffer zones recommendations in the MPEC report. Buffer zones between land where It also commented that in approving manure is applied and watercourses may new livestock operations, planning bodies reduce the risk of contaminants moving should “ensure the availability of a cropped from the land to water. It is thought land base within the region that will allow that permanently vegetated buffer zones application of manure phosphorus at no provide a greater degree of protection more than can be removed by a crop in than zones without such vegetation. The one year” (Manitoba Phosphorus Expert method of application of manure also Committee 2006, 15). increases the risk of contaminants moving The MPEC report also stressed that the off the land. When the manure has been recommendations that it was making could injected or incorporated into the soil after have serious economic consequences for application, there is a lower risk of loss. producers and therefore needed to be phased Taking these factors into consideration, in and coupled with financial incentives.

Table 9.3: Manitoba Phosphorus Expert Committee buffer zone recommendations.

Surface water or surface watercourse feature Buffers Manure application method and setbacks Injection/low level High level broadcast application with application/low level incorporation application with no incorporation Lakes Permanently vegetated buffer strip of 15 metres; no manure application 15-metre setback 30-metre setback Rivers, creeks and large Permanently vegetated unbermed drains buffer strip of 3 metres; no manure application 3-metre setback 10- metre setback Smaller watercourses Permanently vegetated such as roadside ditches buffer strip of 1 metre; that are designated no manure application 1-metre setback 1-metre setback drains, and other lower Manure application order drains setback width with no permanently vegetated buffer 5-metre setback 5-metre setback Source: Manitoba Phosphorus Expert Committee

87 Manitoba Clean Environment Commission

LMMMR amendments based on MPEC and there is adequate crop residue on the recommendations land to control erosion. In November 2006, the Manitoba Outside the RRVSMA, operators with government announced changes to the fewer than 300 animal units are allowed to LMMMR that were based on the MPEC continue to winter apply. As noted above, recommendations and public consultation. operators with between 300 and 400 animal units will no longer be allowed to winter Source factor regulation apply manure after 2010. The LMMMR was amended to adopt the When it came to establishing buffer MPEC recommendations on application rates, zones between manure application and including the allowance for up to five-times different watercourses, the Manitoba application providing no manure be applied government made a number of adjustments during an equivalent number of following to the MPEC recommendation. Where the years. MPEC was requiring permanently vegetated Transport factor regulation buffer zones for large water features such as lakes and rivers, the LMMMR allows for The November 2006 change to the buffer zones that do not have permanent LMMMR also led to the definition of the vegetation. The setbacks for these zones are Red River Valley Special Management Area greater than for the permanently vegetated (RRVSMA) (see Map 9.1). In this area, the zones. For smaller watercourses such as regulation banned winter application and roadside ditches that are designated drains, required that any manure applied between and other drains, the MPEC recommended September 10 and November 10 be either either a one-metre permanently vegetated injected or incorporated into the soil within setback or a five-metre non-permanently 48 hours. Operators are exempt from the vegetated setback. Following consultation injection and incorporation provisions if with producers, the government dropped perennial forages are established on the land the setbacks for smaller watercourses or the soil is not disturbed except for seed recommendation as being impracticable, planting or commercial fertilizer application choosing to continue its prohibition on any application of manure into waterways. Table 9.4 outlines the setback regulations in the Map 9.1 Red River Valley Special Management LMMMR. Area. Phase-in of changes The MPEC had recommended that the changes it was proposing be phased in to allow producers to adjust to the new regulatory regime (See Box 9.2 for estimates on the cost of compliance.) The amendments to the LMMMR adopted this approach. Table 9.5 shows the schedule by which the phosphorus application-rate regulation is being phased in. In setting the phase-in dates, Manitoba Conservation determined that a lengthier period was required for those areas of the province where the amount of phosphorus in the manure produced annually by livestock exceeds twice the crop removal rate: in Source: Manitoba Conservation

88 Environmental Sustainability and Hog Production in Manitoba practice this refers to operations in the rural operators with fewer than 300 animal units municipalities of Hanover and LaBroquerie. will not come into effect until November 10, In addition to this phase-in period, the 2013. ban on winter application in the RRVSMA by

Table 9.4: Manure application setbacks in the Livestock Manure and Mortalities Management Regulation.

Surface water or surface Buffers Manure application method and setbacks watercourse feature Injection/low level High level broadcast application with application/low level incorporation application with no incorporation Lakes Permanently Vegetated 15-metre setback, 30-metre setback, Buffer consisting of 15- including 15- metre permanently metre permanently vegetated buffer vegetated buffer No Permanently Vegetated 20-metre setback 35-metre setback Buffer Rivers, creeks and large Permanently Vegetated 3-metre setback, 10-metre setback, unbermed drains, designated Buffer consisting of including 3-metre as an Order 3 or greater drain 3-metre permanently permanently on plan of Manitoba Water vegetated buffer vegetated buffer Stewardship, Planning and No Permanently Vegetated 8-metre setback 15-metre setback Coordination, that shows Buffer designations of drains All other types of surface water No manure application allowed into these watercourses. (No change from or surface watercourses previous LMMMR).

Table 9.5: Phase-in of phosphorus application provisions of the Livestock Manure and Mortalities Management Regulation.

Type of operation Date by which the operator must be compliance with the regulation New and expanding operations Immediately Existing operations* November 10, 2008 Existing operations that by November 10, 2008, submit November 10, 2013 plans as to how they will achieve compliance with the regulation Operations in areas where the amount of phosphorus November 10, 2015 in the manure produced annually by livestock exceeds twice the crop removal rate Operations in where the amount of phosphorus in the November 10, 2020 manure produced annually by livestock exceeds twice the crop removal rate that by November 10, 2015, submit plans as to how they will achieve compliance with the regulation *Existing means in operation prior to registration of Manitoba Regulation 219/2006.

89 Manitoba Clean Environment Commission

Box 9.2 Cost of compliance that 65 small (under 300 animal unit) Manitoba Agriculture, Food and operations would be affected by the ban Rural Initiatives (MAFRI) has developed on winter application in the RRVSMA. It estimates as to the cost of complying estimated that the cost of developing the with the new phosphorus application needed manure-storage capacity would rate and the ban on winter application. be $40,000 per operation (this does not It is estimated that 93 large (over 300 include the cost of any synthetic covers). animal units) and 75 small (under 300 The estimated cost of compliance with animal units—most of which are located the ban on winter application for those in the rural municipalities of Hanover producers would be $2.6-million. Another and LaBroquerie) do not have access to study has estimated that the cost of the sufficient spread acres to comply with the regulation amounts to between $0.15 to phosphorus-application-rate regulation. $3.50 per marketed hog (Salvano et al. If the operations complied by investing in 2006). A third study indicated that the various manure-treatment and separation cost of moving to a situation where all technologies, MAFRI estimated that the producers applied manure phosphorus average cost per operation of compliance at the plant removal rate would be $28- would be $300,000, with a total cost million (Mann and Grant 2006). of $50.4-million. MAFRI estimated

Comment and the phase-in periods that have been Based on the principles and guidelines developed. While it is not recommending in The Sustainable Development Act, immediate changes to the application-rate the Commission is of the opinion that regulation, it is proposing a change to the sustainable nutrient application policies phase-in dates and a complete ban on winter should: application. Furthermore, the Commission will be recommending that further research • See manure replace synthetic fertilizers and monitoring be undertaken immediately in crop fertilization as much as possible. to prepare for a full-scale review of • See manure phosphorus applied at rates the regulation in five years time, as that do not exceed crop requirements. recommended by the MPEC. There are at least three crucial questions • Decrease the risk of nutrients leaving that need to be addressed by such a review: the land and entering waterways. • Are the LMMMR application-rate The Commission is not convinced thresholds set at the correct levels that the newly introduced phosphorus for long-term protection of the application-rate regulation will ensure the environment? environmental sustainability of the hog- production industry. The Commission has • Is the right tool (in this case, soil test no argument with the central thrust of phosphorus levels) being used to assess the LMMMR phosphorus regulation, which risk? is to bring the application of manure • Where is it appropriate to surface-apply phosphorus into balance with the removal manure? of manure phosphorus. The Commission has reservations about the threshold that has been chosen for achieving that balance

90 Environmental Sustainability and Hog Production in Manitoba

The application-rate thresholds increases, the rate of phosphorus loss The soil test phosphorus measurement in to the environment is likely to increase. parts per million was originally developed to If producers adhere to the minimum assist producers in determining the amount requirements in the current phosphorus of phosphorus they needed to achieve application-rate regulation, only a relatively the desired crop benefit. The Manitoba small number of producers will be required government has produced a soil fertility to reduce their phosphorus application. guide that advises producers as to the Furthermore, given the phase-in periods, recommended quantities of phosphorus they many large-scale producers will not have to should apply to each crop, depending on comply with the regulation until between the soil test phosphorus rating. According 2015 and 2020. to that guide, a 15 ppm soil test phosphorus In developing its recommendations, level is high and a reading of 20 or more is the MPEC had to deal with the fact that described as “very high plus.” Even at the there has been limited research done high rating, the guideline does recommend on the relationship between soil test limited phosphorus application for most phosphorus levels in Manitoba soils and crops. However, for crops such as canola, their relationship to the phosphorus levels mustard, peas, lentils, fieldbeans and in Manitoba waters. Without such research, soybeans, and perennial grasses and forages, it is not possible to develop thresholds with it indicates that there is no agronomic a strong science base. In the face of this benefit from the application of phosphorus lack of research, the MPEC was obliged to when the soil test phosphorus levels are supplement the work done in Manitoba with above 20 ppm (Manitoba Government 2007b, research carried out in other locations and 53). regulations that have been introduced in The application-rate regulation other jurisdictions. Manitoba’s thresholds thresholds of 60, 120, and 180 ppm that are higher than those in some jurisdictions have been adopted in the LMMMR are and lower than those in other jurisdictions. obviously all above the very high plus rate However, comparisons may be of limited of 20 ppm. When one takes into account value without close comparison of a range the phase-in periods, these thresholds will of complicating factors including soil types, have a very limited impact on the current topography, and climate. level of manure phosphorus application to The risk measurement tool Manitoba soils, which is four to five times There is a second significant point of the phosphorus crop-removal rate. The debate when it comes to the Manitoba regulation will allow for continued excess regulation. This concerns the use of soil application of phosphorus. It is only when test phosphorus to measure the risk of the 120 ppm is reached that operators need phosphorus loss. The soil test phosphorus to reduce their application to one-times the measures have a number of advantages. phosphorus crop-removal rate. They are well understood in the agricultural This approach is further complicated community, where they are used to by the lack of scientific evidence to determine whether there is a need to support the view that, at levels up to 120- add phosphorus to the soil and, when ppm, phosphorus did not leave the soil. used in the LMMMR, it is a simple and The evidence that does exist suggests straightforward tool. Research suggests that, that phosphorus leaves the soil at all in Manitoba conditions, they may provide an levels, although the soil’s ability to retain effective measure of risk (Rawluk and Flaten phosphorus decreases as the amount of 2007). phosphorus in the soil increases. As the An alternative tool is a phosphorus rate of phosphorus application to the soil index; such an index would use the relevant

91 Manitoba Clean Environment Commission source and transport indicators (for example, been the most appropriate crops to grow on rate of application, type of application, marginal soils, which often have high risk of erosion, rainfall) of phosphorus loss under leaching and runoff. local conditions in determining the risk Pastures are usually developed on assessment. The phosphorus indices that marginal soils, which have low nutrient have been developed elsewhere are not absorption capability and relatively high currently applicable in Manitoba (they rates of runoff. This is compounded by pay little attention to snowmelt and livestock activity that compacts the soil. The considerable attention to rainfall, which compacted trails leading directly to a water is far less plentiful in Manitoba than in source may serve as a pathway to nutrient many jurisdictions that have developed deposition in surface waters. It has been indices). When these indices have been traditional practice in Manitoba agriculture applied to Manitoba, they have significantly to develop pastures on land with year round underestimated the potential risk of manure access to surface water. phosphorus loss (Nicolas et al. 2002). The Manitoba Livestock Manure Another proposed risk measurement Management Initiative has supported tool is the degree of soil saturation. This research on hog manure application to measures the soil’s capacity to retain grassland and pasture over a three-year phosphorus and the degree to which this period. Preliminary results of this research capacity has been saturated. It is argued are now becoming available. These studies that it is a more accurate determinant of show that surface application of hog manure whether or not the phosphorus is going to has greatly increased the production of be lost. haylands but has not resulted in the same It may be the case that soil test gains on pastures. These studies also raised phosphorus, on its own, may be able to some concerns that should be addressed predict the risk of manure phosphorus loss before surface application of hog manure for the major routes in Manitoba. However, is further promoted on grasslands and the debate on this issue remains open. pastures. Nutrients are remaining in the top layers of soil in both the haylands and Surface application of manure pasture, and are therefore vulnerable to The Commission was informed that runoff. The greatest build up of nutrients most of the liquefied manure that is applied was found on bare areas where livestock to land as fertilizer is either injected traffic was more intense, even though the or incorporated. The exceptions include researchers avoided the application of grasslands, forage fields, and pastures, manure in these areas (Ominski 2007). where the common method of application There needs to be further research into is surface application. Traditionally these all three issues: the phosphorus thresholds, crops would only receive synthetic fertilizer the risk assessment tool, and surface (usually nitrogen) when grown on moist application. The Commission believes that soils and when hay and forage prices were future research will, in all likelihood, lead high. Otherwise, there was little economic to regulatory changes that require operators benefit to be received from fertilizing to achieve balance at lower threshold them. Many crops grown on these fields, levels than are mandated by the current particularly grasses, do use considerable regulation. amounts of nitrogen but have a low need for Other issues phosphorus, while others such as alfalfa and In addition, to these three overarching leguminous crops do not require nitrogen concerns, the Commission also has identified but need limited amounts of phosphorus. these issues: Grass and forage crops have traditionally

92 Environmental Sustainability and Hog Production in Manitoba

• The lengthy phase-in dates for the the risk of direct phosphorus addition to regulation on manure application surface water bodies. rates, particularly in the intensively developed areas. The phase-in dates Comment are very generous, particularly for the The Commission has identified a number intensively developed areas. It may of serious concerns with the provisions in not be until 2020 that operations in the LMMMR for the regulation of manure these areas (which account for a quarter phosphorus. At the heart of all the of the provinceís hogs) will be in Commissionís concerns is a recognition that compliance with the regulation. presently and for a considerable period of • The up to five-times crop-removal time to come, phosphorus will be applied at rate exemption. While the operator a rate greater than the crop-removal rate. cannot reapply manure until the soil In short, it will be applied in an inefficient test phosphorus level returns to an manner, will not displace as much synthetic adequate level, overapplying manure in fertilizer use as is possible, and is at greater this manner increases the amount of risk of entering Manitoba waterways. nutrients that is at risk of being lost. Furthermore, it is not likely to contribute to the rehabilitation of those watercourses that • The lengthy phase-in period of the are already experiencing eutrophication. ban on winter application by operators These criticisms must be balanced by the under 300 animal units in the RRVSMA recognition that the phosphorus regulation (it does not come into effect until is an important first step in addressing November 2013). Winter applied manure the imbalance in manure phosphorus use is at great risk of nutrient loss. in Manitoba. Only two other Canadian jurisdictions regulate phosphorus, and the • The lack of restriction on winter Manitoba regulation appears to compare application by operators with fewer than well with those in other locations. Second, 300-animal units outside the RRVSMA. the regulation has been developed with Again, winter-applied manure is at great consideration for a range of social and risk of loss. economic factors, that the Commission is not • The lack of restrictions on fall directly considering in this Investigation. application outside the RRVSMA. The Commission notes that the current Nutrients in fall-applied manure that regulations were developed by an expert are not injected or incorporated have an committee, have been endorsed by the Lake elevated risk of loss. Winnipeg Stewardship Board, and were adopted only after public consultation. • The lack of restrictions on fall Finally, the limited amount of hard data application to perennial forages. There relating to phosphorus loss in Manitoba is an elevated risk of loss of nutrients means that the Commission is not in a under these conditions. position to recommend an alternate set of thresholds, risk criteria, or buffer zones. • The lack of restrictions on application For these reasons, the Commission is on pasture. There is an elevated risk for not recommending that the phosphorus loss of nutrients under these conditions. regulation be abandoned. The Commission is however recommending that the phase-in • The lack of buffer zones for smaller period be shortened, with full compliance watercourses. The buffer zones proposed being required by 2013. Secondly, the by the MPEC were intended to reduce Commission is calling on a complete ban on

93 Manitoba Clean Environment Commission winter application of manure throughout Commission believes that operators who the province. This is consistent with the were operating in compliance with existing thrust of the recent Auditor General’s report, regulations should be aided in making the which recommended that the limits on the transition to the new rules. For this reason application of manure on frozen or snow- it recommends that the government provide covered ground should apply to all livestock operators with the assistance or incentives operations. needed to bring their operations into The Commission is also recommending conformity with the new regulation. that the government implement the final There is a strong possibility that the two recommendations in the MPEC report. five-year review of the regulation will Those recommendations read as follows: lead to the adoption of an even stricter regulation. If such changes are adopted, 3.1 The Minister of Conservation should they will likely have an additional negative review the effectiveness of the new impact on producers and future assistance phosphorus-based regulation no later may be required. The Commission believes than five years after its coming into that one way of limiting the need for force. such assistance is to require that all new or expanding livestock operations be able 3.2 Manitoba Conservation should work demonstrate that they have access to with other organizations to develop enough land to apply manure phosphorus science-based, environmentally at the one-crop-removal rate. Both the and economically sound beneficial MPEC and the Lake Winnipeg Stewardship management practices for reducing Board made this recommendation in their phosphorus losses to surface waters reports. The Commission believes that the under Manitoba’s soil, landscape, and recommendation is in keeping with concepts climatic conditions. of sustainability, efficient use of resources, and environmental protection. It is imperative that the government The over-application of phosphorus undertake the five-year review. Furthermore, is exacerbated by the fact that nitrogen the Commission believes that no satisfactory from manure is lost to the atmosphere review of the regulation can take place during storage and application. This loss without considerably more research being contributes to both the odour complaints undertaken in advance to determine the and the increase in greenhouse gases. It can appropriateness of the threshold and risk be addressed by the use of synthetic covers measures. For this reason, the Commission for storage facilities and the injection or is recommending that the Manitoba incorporation of manure when applied. This government ensure that the appropriate will be further addressed in Chapter 10. scientific research and monitoring The government should assist producers commences immediately and is completed in efforts to adopt and develop techniques in time for the five-year review of the that reduce the liquid volume of manure. phosphorus regulation. Such measures would reduce the cost of The Commission has, for the most part, transporting nutrients, resulting in more not dealt with social and economic issues. effective use of manure nutrients and a However, the Commission recognizes that reduction in the pressure to convert natural the current phosphorus regulation will have lands to croplands. a negative economic impact on operators. While spring application is preferable for When the government announced the the control of nutrient loss, the Commission changes to the regulation in November recognizes that, from a producer perspective, 2006, it stated that there would be financial spring application presents a number of assistance to help operators adjust. The

94 Environmental Sustainability and Hog Production in Manitoba serious problems given the limited period of efforts needed to acquire these data time that exists between thaw and the time should commence immediately. by which they must have their fields seeded. Government and industry should encourage 9.4 The Manitoba government immediately producers to move to barn and manure- conduct, facilitate, collaborate on storage facility management that maximizes and commission research on soil test spring and summer supply and application. phosphorus and transport mechanisms that will lead to the calculation of a Recommendations phosphorus threshold specifically for Manitoba soils and climatic conditions. 9.1 The phase-in dates for the Livestock This research should include an Manure and Mortalities Management examination of the effectiveness of a Regulation phosphorus provisions phosphorus index for Manitoba. This be adjusted so that all operators are threshold should be considered in the required to be fully compliant with the review of the phosphorus regulation. regulation by 2013. 9.5 The Manitoba government work 9.2 The ban on the winter application of with other organizations to develop manure in the Livestock Manure and science-based, environmentally, Mortalities Management Regulation be and economically sound beneficial extended to all operations by 2013. management practices for reducing phosphorus losses to surface waters 9.3 The Manitoba government undertake a under Manitoba’s soil, landscape, and review of the phosphorus application climatic conditions. provisions of the Livestock Mortalities and Manure Management Regulation 9.6 The Manitoba government provide after the regulation has been in place livestock operators with financial for five years. The review should include: assistance or incentives to assist them in coming into compliance with the • Trends in soil test phosphorus by phosphorus provisions of the Livestock region. Manure and Mortalities Management • Enforcement effectiveness and Regulation. This should include funding compliance. for the implementation of effective beneficial management practices. • Effects of soil test phosphorus values on adjacent watercourses/water 9.7 The Manitoba government amend quality. the Livestock Manure and Mortalities Management Regulation to require • Evaluation of thresholds. that new and expanding operations be • Evaluation of risk assessment tools. required to demonstrate that they have a sufficient cropped land base available • Evaluation of management practices to balance phosphorus application rates to reduce phosphorus-related with removal rates over the long-term. environmental risks. 9.8 The Manitoba government and industry Such a review will depend on the encourage producers to move to barn availability of a wide range of water and manure-storage facility management quality data. The water monitoring that maximizes spring and summer supply and application.

95 Manitoba Clean Environment Commission 9.9 The Manitoba government facilitate, is also banned in nutrient buffer zones. encourage, and undertake further studies Manure-storage facilities, confined livestock into the cumulative effects of applying areas, septic fields, sewage treatment plants, manure fertilizer to marginal lands. and wastewater treatment lagoons are not This should include the examinations of to be located in Zone N4 and in Nutrient pathogen movement and transfer, and Buffer Zones. Operators who have manure nutrient run-off. management plans registered under the LMMMR are exempt from the regulation for 9.10 The Manitoba government assist the lands on which they spread manure. producers in efforts to adopt and The zones are based on a number of develop techniques that reduce the factors such as slope, topography, soil liquid volume of manure. Such measures texture, erosion, soil characteristics, and would reduce the cost of transporting crop yield. Zone N1 is made up of what nutrients, resulting in more effective are described as highly productive lands use of manure nutrients and a reduction and accounts for 60 per cent of the land in the pressure to convert natural lands in central and southern Manitoba. Zone to croplands. N2 is made of up of land with moderately productive soils and accounts for 11 per Nutrient Management Regulation cent of central and southern Manitoba, while Zone N3 is marginally productive land While Manitoba has been regulating and accounts for 10 per cent of central and the application of the nutrients in manure southern Manitoba. Zone N5 is made up of since 1998, it currently does not regulate urban and built up areas. the application of the nutrients contained in Zone N4 is non-productive land with synthetic fertilizers. This lack of regulation a high risk of loss of nutrients. It covers of synthetic fertilizers was one of the issues approximately 16 per cent of central and identified in the recent Auditor General’s southern Manitoba. Nutrient buffer zones report. This will change when the Nutrient include lakes, reservoirs, rivers, creeks, or Management Regulation (NMR) of The streams, drains and ditches, major wetlands, Water Protection Act comes into effect. The bogs, marshes or swamps, and constructed regulation will be phased in, and is expected stormwater retention ponds. to be in full effect by January 1, 2011. While the LMMMR uses agricultural The NMR focuses on the application capability classifications for determining of substances containing nitrogen and nutrient application rates for different areas phosphorus to the land and limits the of the province, the NMR’s zones and the establishment of certain types of nutrient LMMMR’s classification are in large measure generating facilities (such as manure-storage the same. facilities, confined livestock areas, sewage treatment plants, and wastewater treatment Nutrient application lagoons) in environmentally sensitive areas. The zones that it establishes are all in For nutrient application, the NMR southern Manitoba and a separate regulation sets essentially the same limits for the will be developed for northern Manitoba. application of nitrogen and phosphorus that The Regulation establishes six different are found in the LMMMR. It also introduces Water Quality Management Zones for the concept of a nutrient management plan, Nutrient Management: N1 through N5, and a which is similar to manure management sixth category for nutrient buffer zones. In plans. Unlike manure management plans, zones N1-N3, nutrient application is allowed, nutrient management plans are only while in N4-N5, it is not allowed. Application mandatory for existing operators who are applying nutrients in Zone N4 (new or

96 Environmental Sustainability and Hog Production in Manitoba expanding operators are not allowed to apply or swamps, but these setbacks were dropped nutrients in Zone N4). In zones N1 to N3, during the consultation process. operators do not have to register nutrient management plans as long as they are Small livestock operators applying nutrients at a rate that does not The NMR applies to those livestock exceed the nitrogen and phosphorus limits. operators with fewer than 300 animal units Golf courses are also required to establish (since they are not required to register nutrient management plans. plans under the LMMMR). This is not a significant change, since these operators are Nutrient buffer zones currently subject to the LMMMR nitrogen Nutrient buffer zones include lakes, and phosphorus regulations. They will be reservoirs, rivers, creeks, streams, drains, required to file nutrient management plans ditches, and a variety of wetlands. The if they are currently applying manure on regulation outlines distances that must be land in Zone N4. maintained between these zones and the application of nutrients. These distances Comment are increased in the case of those lakes, In large measure, the NMR simply reservoirs, rivers, creeks, and streams extends the provisions of the LMMMR to that the government has designated as sectors of Manitoba society that apply vulnerable. These setback distances are in nutrients to land. This is a positive measure. essence the same as appear in the LMMMR. However, there are minor differences Table 9.6 outlines the nutrient application in terms used in the regulations (For distances in the NMR. It can be compared example, NMR uses the concept of zones with the set distances in the LMMMR in and vulnerable watercourses, while the Table 9.4. As with the LMMMR setbacks, it LMMMR does not.) These variances may had originally been proposed that there be unnecessarily complicate the lives of setback distances for the smaller drains and producers. Complications could arise if two ditches and minor wetlands, bogs, marshes different departments, Water Stewardship

Table 9.6: Nutrient application setback levels in the Nutrient Management Regulation.

Nutrient application Nutrient application setback width if the setback if the applicable applicable area is covered area has no permanent Water body with permanent Vegetation vegetation A lake or reservoir designated as vulnerable 30 metres 35 metres A lake or reservoir (not including a constructed 15 metres 20 metres stormwater retention pond) not designated as vulnerable A river, creek or stream designated as vulnerable A river, creek or stream not designated as 3 metres 8 metres vulnerable An order 3, 4, 5, or 6 drain A major wetland, bog, marsh or swamp A constructed stormwater retention pond A groundwater feature 15 metres 20 metres

Minor drains and roadside ditches No application to the edge of the water drain or ditch. Minor wetland, bog, marsh, or swamp No application to the edge of the high water mark.

97 Manitoba Clean Environment Commission and Conservation, end up enforcing what to agricultural land. (Lake Winnipeg is in many ways the same regulation on Stewardship Board 2006, 65) the same operation at the same time. As much as possible, the Commission would The tools and a good deal of the data prefer to see more uniformity in regulation (municipal wastewater treatment effluents, and enforcement, possibly culminating in synthetic fertilizer application figures, land a single regulation dealing with nutrient livestock manure application contributions) application to land. At the very least, required to develop such a budget already there should be common systems of exists. This information should be used to classification and administration. Given develop nutrient budgets for agricultural that currently Manitoba Conservation has Manitoba on a sub-watershed and ultimately the responsibility and authority to enforce a watershed basis. This information the LMMMR, it might be appropriate to would play an invaluable role in assisting also have Conservation responsible for the producers in selecting appropriate nutrient administration and enforcement of the NMR. management practices and in determining siting decisions for future hog-production Recommendation operations. Without such budgets, there is a limited ability to assess the cumulative 9.11 The Manitoba Government reconcile the impact of proposed hog-production differences in terminology (particularly operations on a local and downstream basis. in relation to zones and classifications) Nutrient budgets would be an important in the Livestock Mortalities and Manure element in the development of the sort of Management Regulation and the watershed planning that is envisioned under Nutrient Management Regulation. The Water Protection Act that is discussed in Chapter 12. They would provide a framework Nutrient budgets within which Conservation Districts and other water management and planning Nutrient budgets quantify the nutrients authorities could reduce nutrient loss to entering and leaving a system, making it the environment. The Watershed Institute possible to better understand and control proposed in Chapter 13 could play an their flow. They constitute a useful tool in important role in developing such budgets. ensuring that nutrients are managed in an environmentally sustainable manner. These Recommendation budgets are important farm level tools, but they also can be developed on a regional or 9.12 The Manitoba government develop watershed basis. In its 2006 report, the Lake a nutrient budget for agricultural Winnipeg Stewardship Board recommended Manitoba on a sub-watershed and, that: ultimately, a watershed basis. A terrestrial nutrient budget should be developed for Manitoba that would Pathogens consider all agricultural nutrient sources Hogs, along with many other types such as manure, feed, and inorganic of animals, can be hosts to pathogens fertilizer, as well as all agricultural (viruses, parasites, and bacteria) that can nutrient exports such as harvested grain, cause foodborne and waterborne diseases crop residue removal, sales of animals, in human beings. Hogs excrete these milk and eggs. It is essential that the pathogens, and as a result, hog manure terrestrial nutrient balance be considered can serve as a step in the route that when intensive operations are being these pathogens can travel from hogs to sited and when manure is being applied human beings. The potential also exists for

98 Environmental Sustainability and Hog Production in Manitoba pathogens in manure that is surface applied Produce that is consumed without being consumed by wild animals that are cooking is at particular risk of pathogen grazing on pastures and forage fields. While contamination, since once it is contaminated farmers keep their animals off manured with pathogens it cannot be rendered fields until the pathogens are likely to have safe for consumption (Holley et al. 2007). died, it is impossible to manage wild animals In Manitoba, manure is largely used to in this way. Resident and transitory wildlife, fertilize grain and cereal crops and forages. such as moose, deer, elk, birds and rodents Potatoes are the only vegetable fertilized often feed, graze and make their homes in with liquefied manure, but because potatoes pastures. In some cases, the animals may are grown below ground and cooked before not develop an illness, but may serve as a being eaten, the pathogens do not represent reservoir for the pathogen. a health risk. While there is no prohibition A paper prepared for the Commission against using manure on fruits and leafy concluded that, “The way hog manure vegetables, provincial guidelines recommend is handled on farms in Manitoba has the against the practice. potential to cause adverse environmental effects through pathogen contamination of Pathogen regulation plants and water” (Holley et al. 2007, 305). There are no federal or provincial While pathogens cannot live indefinitely standards for pathogen reduction or hygiene in manure, the fact that liquefied manure- standards for animal manures that are to storage facilities regularly receive fresh be applied as fertilizers. However, a number inputs of manure means that the facilities of provincial policies related to manure are rarely, if ever, pathogen-free. Commonly, storage and handling may provide a measure the pathogen level reaches a stable state in of protection against the risk presented by the manure. Those operations with multi- pathogens. All measures intended to halt the cell lagoons have the capacity to reduce the movement of manure into waterways serve pathogen content of the manure if they are to reduce contamination pathogen risks. managed in an appropriate manner (Holley These would include the setback distances et al. 2007). from watercourses and water sources in Without additional treatment, which siting regulations, the regulations regarding most Manitoba operations do not engage in, the integrity of manure-storage facilities, pathogens will be present in manure applied and the buffer zones established between to land. There, they are at risk of moving watercourses and manure application. The into surface water, groundwater, or being ban on winter application in certain zones taken up by animals grazing on pastures. and the new restrictions on fall application Once they are applied to the fields, the will provide additional protection. There pathogens can survive for approximately 30 is also research that suggests that when days. Pathogens in manure that is injected manure is applied at agronomic levels or incorporated are likely to survive for (matching crop-removal rates) pathogens longer periods than pathogens in surface- have shorter survival periods (Holley et al. applied manure. However, pathogens in 2007). While it is not required by regulation, injected or incorporated manure are less the province does recommend that there susceptible to moving off the land with be a 30-day delay between the time of runoff and contaminating surface water. application of manure to a pasture and the Research indicates that from the perspective time livestock are allowed to graze on the of pathogen control, spring is the most field (Holley et al. 2007). appropriate time to apply manure (Holley et It should also be noted that pathogens, al. 2007). because of their relatively short life spans,

99 Manitoba Clean Environment Commission present a greater risk to surface water than phosphorus limits governing manure to groundwater. application in Manitoba and studies Aside from these measures to reduce of transfer mechanisms. the pathogen transit risk, measures can also be employed to treat manure to reduce • Practices and technologies that will pathogen presence. In some European effectively reduce or eliminate the jurisdictions, regulations are in place for the pathogen content in agricultural treatment of manure before it is transported manure in Manitoba. This off the property. Currently, some Manitoba should include research into the hog producers treat and largely eliminate effectiveness of multi-cell storage pathogens through composting. Potential facilities and whether treatment of treatment measures for liquefied manure manure with ammonia or urea can include: aerating liquid hog manure, treating eliminate pathogens from livestock with ammonia or urea in covered manure- manure in Manitoba. storage facilities, and, with appropriate • The pathogen related-risks facing management techniques, storing in multi- hog-production workers and steps cell manure-storage facilities. that can be taken to eliminate and reduce those risks. Comment The Commission recognizes that • The incidence of pathogen-related pathogen control is an important public- illness and the connection between health issue. While the hog industry is a such illnesses and the livestock potential source of pathogens that can cause sector. human illness, the Commission has not been presented with evidence to suggest that this • How pathogens in manure fertilizer, risk constitutes a barrier to the industry’s particularly surface-applied fertilizer, environmental sustainability. This does may affect wildlife. not mean that the risk posed by pathogens could not become more severe or that more Heavy metals steps should not be taken to reduce that Studies suggest that Manitoba hog risk. Further research is needed to determine manure can contain a large number of the extent to which current management minerals and heavy metals. The levels vary practices intended to control nutrients can dependent upon the amount of metal that also control pathogens. Second, there is a has been added to the feed and the type need for research to identify appropriate of hog production being carried out at any manure-treatment strategies for Manitoba. given location. Minerals can be added to feed as a growth promotant and to reduce Recommendation disease. Currently there are no federal or 9.13 The Manitoba government facilitate, provincial standards for the level of heavy encourage, and undertake further studies metals in hog manure that is applied to to identify: the soil. Research suggests that most • Practices and technologies that can metals are present at such low levels that further protect the environment, it would take over a century of application animals and humans from pathogen for them to reach levels that present an distribution from hog production. environmental problem. However, depending This should include determining on the manure, boron, copper, and zinc the role played by the nitrogen and are present at higher levels. These metals can make a positive contribution to soil

100 Environmental Sustainability and Hog Production in Manitoba fertility if they are applied to soils that 9.1.2 Manure storage are mineral deficient. Currently, however, It is estimated that the Manitoba hog- hog operations are not sited on the basis production industry produces 3.8 million of the mineral deficiency of adjacent soils tonnes of manure a year (Honey, personal and manure transport costs are high. While communication 2007). The majority of this crops do remove metals, the application of manure is liquefied and applied on fields some minerals can exceed the crop-removal as fertilizer. A smaller portion is stored rates. In short, whether or not heavy metals as solid manure (and is often composted) build up in soils depends in large measure and applied to fields as fertilizer. Some on the feed, the types of operations in the operations do not have large-scale manure- province, the soils on which the metals are storage facilities and therefore apply manure applied, and the crops that are grown on on a year-round basis. Operations with more those soils (Racz and Fitzgerald 2001). than 300 animal units are banned from Studies also suggest that applying applying manure during winter months manure at the phosphorus crop-removal rate and (along with many operations that significantly reduces the risk of a build up have less than 300 animal units) require of heavy metals in soils (Rawluk and Flaten long-term manure storage. Since 1994, the 2007). The presence of metal in manure can Manitoba government has mandated that also be reduced by decreasing the metal earthen manure-storage facilities undergo content of feeds. This requires producers a provincial permitting process prior to to adopt different approaches to disease construction. A requirement for permits for management and growth promotion. concrete or steel tanks for manure storage There is currently no evidence to was added in 1998. Livestock operators are indicate that heavy metals represent a prohibited from commencing construction threat to the environmental sustainability of a new storage facility or expansion and of the hog-production industry. Second, modification of an existing facility until moves to reduce the application rates they have received a permit under the of phosphorus are likely to reduce the LMMMR. It should be noted that while application of metals. Technologies that these facilities are often referred to as separate manure into liquid and solid lagoons, technically, they are not lagoons, portions also concentrate the metals in since they are not designed to encourage the smaller, solid portion. This allows treatment of the manure (although some for low-cost transportation of the metals treatment may take place). According to locations where the soils are mineral to Manitoba Conservation, there are 675 deficient. permitted manure-storage facilities in The Commission believes that it is Manitoba. Hog-production operations have important to develop a better understanding permits for 540 of these facilities, while of the background levels of heavy metals in nine more facilities are operated by mixed Manitoba soils, particularly on fields that are hog and other livestock operations. Included being fertilized with hog manure. in the 540 total are 48 concrete storage facilities and 19 steel storage facilities. In Recommendation short, approximately one half of the hog operations store manure in liquefied form 9.14 The Manitoba government facilitate, in permitted manure-storage facilities. encourage, and undertake further studies Approximately 150 producers operate hoop in the assessment of heavy metals in barn structures and store their manure in Manitoba agricultural soils and potential dry form. As discussed below, there may environmental effects as a result of be up to 800 manure storage facilities long-term application of manure. that were constructed prior to 1994, with

101 Manitoba Clean Environment Commission approximately 600 of them being used to of soil samples for further analysis are store hog manure. required for earthen storages. The location Because the bulk of Manitoba manure and level of protection that will be required is stored in liquefied form, the rest of the is based on information from these test discussion of manure storage will focus on holes, including type of soil, depth to water facilities designed to store liquefied manure. table, and estimate of soil permeability. The design of the manure-storage facility should Types of manure storage systems include a site plan, capacity for present and allowed future needs, level of protection required, The most common types of manure- laboratory results of the soil sampling storage facilities that are permitted are: from initial test holes, and other pertinent information. A) An earthen storage area with a straight cut-and-fill construction where there Site categories is adequate clay of suitable quality underlying the facility. The selection and design of a manure- storage structure varies depending on the B) An earthen storage area with imported characteristics of the site. Sites are classified clay liner when adequate clay of as Geologically Secure, Geologically Variable suitable quality is hauled in from or Uniform, or Geologically Sensitive. elsewhere on site or from another A geologically secure site is one that is location. separated from an aquifer by five metres of low permeability material measured C) A earthen-base storage area with a from the floor of the storage structure plastic liner, which may consist of to the aquifer. This material must have either a polyvinyl chloride (PVC) liner of conductivity no greater than 1x10¯9 metres minimum .76 millimetres thickness or a per second (this is equivalent to an annual high-density polyethylene (HDPE) liner flow of 3.15 centimetres). While site-specific of minimum 1.52 millimetres thickness. studies are required, these sites are usually suitable for unlined earthen storage systems. D) A concrete storage unit that is either Groundwater monitoring wells and plans are pre-cast or poured in-place. usually not required. E) A steel storage tank. A geologically variable or uniform site is one where low permeability fine-grained Design requirements soils exist with interstratified coarse- grained soils that may permit appreciable The LMMMR requires that the design water flow to or from adjacent aquifers. ensure that the storage facility can prevent This category also includes areas of uniform the escape of any livestock manure that geological formations consisting of fine- may cause pollution of surface water, grained soils with permeability greater than groundwater, or soil. A professional 1x10-9 metres per second and a minimum of engineer must undertake an initial site five metres of overburden from the floor of assessment and determine soil geotechnical the manure structure to an aquifer. In the characteristics as background information case of a geologically variable formation, a for the manure-storage facility design suitable impervious layer must be placed proposed. A professional engineer must sign between the bottom of the manure-storage off on documents, designs, drawings, and structure and an existing aquifer. This may final certification. A minimum of three test be accomplished either through the use of a holes, drilled to a recommended depth of one metre compacted clay or clay till layer not less than 9.15 metres, and the collection with a permeability no greater than 1x10¯9

102 Environmental Sustainability and Hog Production in Manitoba metres per second or the use of a synthetic concrete and steel manure storages and 400 liner. When synthetic liners are used, a days for earthen manure-storage facilities. venting system to prevent air and or gas build up between the earthen floor of the Setbacks structure and the liner must be installed. The regulation states that the facility must In addition, the permit may require a be at least: groundwater-monitoring plan, including groundwater-monitoring wells. a) 100 metres from any surface A geologically sensitive site is one that watercourse. contains permeable formations (coarse-grained soils) or complex geology with interbedded b) 100 metres from any sinkhole, spring or clay and sand or gravel strata where there well. is less than five metres of overburden or no overburden of low permeability material c) 100 metres from the boundaries of the from the floor of the manure-storage structure agricultural operation. to an aquifer. Engineered steel or concrete storage structures are usually selected for Monitoring wells geologically sensitive sites. Earthen manure- There are two different sets of water storage structure options are limited and monitoring requirements. The first set, the require advanced design including synthetic monitoring of the livestock’s drinking water or composite liners, secondary containment source, is mandatory for all operations and leachate detection systems that are placed over 300 animal units. The second set of immediately below the floor. A monitoring monitoring wells can be required adjacent to system including groundwater monitoring manure-storage facilities. In practice, such wells is required. monitoring wells are usually only required Facilities in the 100-year flood plain in the case of storage systems with clay or must have flood protection at least 0.6 plastic liners or in-ground concrete and steel metres higher than the 100-year flood water storage systems (most concrete and steel level (or what the director deems to be systems are above ground and no monitoring adequate protection). This does not apply to wells are required). Partially buried concrete storage facilities constructed prior to 1998. or steel tanks have weeping tile installed While there are no minimum capacity around the base of the perimeter that requirements defined in the regulation for directs seepage to a sump, which acts as a manure storage capacity, an operator is monitoring facility. required to have enough capacity to ensure Water analysis reports from these wells that all of the livestock manure produced must be submitted annually to Manitoba or used in the agricultural operation can be Conservation. The source water monitoring stored until it can be applied to the fields well reports are submitted to Manitoba or removed from the facility. The lack of Conservation in Winnipeg, where the specific capacity requirements in the LMMMR information is entered into a database. was identified by the Auditor General as This information has only been collected a limitation in the Manitoba regulation since 2004. The monitoring well reports are in comparison with requirements in other submitted to regional Conservation offices, Canadian jurisdictions. In its response to where they are entered into a provincial the audit, Manitoba Conservation stated database. This information has been that this had been addressed through collected since 1998. improvements in design guidelines. Manitoba The director may require an operator Conservation technical reference guidelines to implement a monitoring and reporting specify a minimum capacity of 200 days for program if the director believes that

103 Manitoba Clean Environment Commission the storage, handling, and management acreage for application of manure. Signed of livestock manure in the agricultural agreements with the owners, authorizing operation is causing or would likely cause manure application to lands leased for this pollution of surface water, groundwater, or purpose must also be provided. Conservation soil. expects operators to be able to demonstrate that they have access to enough land to apply Requirements manure at two-times the phosphorus crop- An applicant for a manure-storage removal rate. The exceptions to this are in facility permit (who had received the Hanover and LaBroquerie, where the amount appropriate municipal approvals) is entitled of livestock manure produced exceeds two to a permit if: times the crop removal rate. In these cases, Conservation requires that the operator have • The proposal conforms to Manitoba enough land to apply at the one-time crop- Conservation’s siting and construction removal rate. Manitoba Conservation will not requirements. consider land in which the phosphorus level • There is sufficient suitable land exceeds 60 ppm phosphorus in the calculation available to the operator to implement for estimating spread land availability. an appropriate manure management plan. Approval steps The livestock manure-storage facility • The construction, modification, or permit approval includes the following steps: expansion of the manure-storage • A Conservation engineer makes an facility can be carried out in a manner initial review of the completed Permit that ensures that the environment is Application Form and supporting protected in the event of a structural information to ensure compliance failure of the facility. with all regulatory requirements and • The construction, modification, accepted construction standards, notes or expansion can be carried out deficiencies, and assigns the application in a manner that ensures that the to an Environment Officer. environment is protected in the case • The Environment Officer reviews the of a manure-storage facility located on documentation, identifies deficiencies, land: and forwards all deficiencies to the (A) that consists of sand and gravel, applicant. (B) in which an aquifer exists when less than five metres of overburden having an • When the applicant responds, the expected hydraulic conductivity of 1 x 10-9 Environment Officer reviews the metres per second or less will separate the information to determine if all bottom of the facility from the top of the deficiencies have been addressed, and uppermost underlying aquifer or fractured to see if the applicant has received rock, municipal approval and applied for a (C) that is within the unsaturated Water Rights License (if necessary). If portion of an aquifer. the application is acceptable for the site conditions, the Environment Officer Manure management prior to drafts a permit and transmittal letter. construction • The application for the permit requires Prior to the granting of a manure- the proponent to identify whether or storage facility permit, the proponent must not a TRC was prepared and to attach demonstrate access to available suitable

104 Environmental Sustainability and Hog Production in Manitoba

a copy of the Conditional Use Permit. of construction. The Environment Officer Manitoba Conservation verifies if the inspections are supposed to involve a proponent has obtained relevant local minimum of one visit prior to construction, approvals. one visit during construction, and one visit following construction. However, the • A Conservation Engineer reviews the Auditor General reported that in 50 per cent application and, if satisfied with the of the cases reviewed there had been no application, signs the transmittal letter pre-construction inspection and in 42 per and makes a recommendation to the cent of the cases there had been no post- Regional Director. construction inspection. The Auditor General also recommended that in future, applicants • The Regional Director reviews the be given written inspection reports after application and, if satisfied with the each inspection. application, signs the permit and Following the final inspection, a approves the transmittal letter. professional engineer must submit a written • A permit for construction (or certification and an engineering report to modification or expansion) is issued to the owner and to Manitoba Conservation the applicant. Copies are sent to the indicating whether the construction is proponent’s engineering consultant, in compliance with the requirements of and the municipality where the storage the LMMMR and that the approved design facility is to be located. plan was followed. The operator can put the manure-storage facility into operation Normally, a site visit is undertaken during upon receipt of a letter from Manitoba the application review process. Conservation indicating acceptance of the Water Stewardship conducts a land base engineer’s certification. analysis, calculates land-base requirements for manure application, and reviews the Decommissioning a manure-storage current soil test data. Conservation also facility provides Water Stewardship with a copy of If livestock production is discontinued the draft permit for review. or a manure-storage facility is not in Another concern raised by the Auditor active service for more than one year, the General in relation to the approval process operator is required to inform Manitoba was the fact that, at the design stage, Conservation how the integrity of the there may be considerable changes to the facility will be maintained or how it will proposed storage capacity of the manure- be decommissioned. These plans require storage facility. In such cases, the Auditor the approval of Manitoba Conservation. General stated that Conservation should be Currently, few facilities in Manitoba have obliged to inform the relevant municipality been decommissioned. In the event of a of all significant design changes. decommissioning, the liquid manure and any manure solids accumulated on the floor must Construction/modification/expansion of be removed and disposed of in a manner a manure-storage facility that complies with the LMMMR nutrient Unless otherwise approved by the application rates. As these structures age, Director, construction must take place more of them will be decommissioned, and between May 1 and October 31, with advance a detailed decommissioning policy may be notice being given to the local Environment required. Officer. Environment Officers and the design engineer are to carry out regular inspections during construction and upon completion

105 Manitoba Clean Environment Commission Appeals of permit decisions springs, sinkholes, groundwater or other Under The Environment Act, any person environmentally sensitive areas. It can affected by a permit issued by the director also order the provision of environmental (or the refusal to issue a permit) or the protection of nearby watercourses and other limits, terms and conditions in a licence or environmentally sensitive areas, repairs, and permit, can make an appeal to the minister modifications. responsible for The Environment Act. The The condition of these non-permitted appeal must be made within 30 days of facilities is a serious concern for the the granting of a permit. When a permit is Commission. These are aging structures that granted, the rural municipal government were constructed at a time when there were is normally advised. Applications for no design requirements or approval process permits are not public documents, and, in place. Manitoba Conservation estimates in many cases, the only condition in the that there may be as many as 800 non- permit pertaining to the design is that the permitted facilities. The Auditor General’s facility must be constructed as described report indicated that in 2005, Manitoba in the application. Since 1998, there Conservation did not have a well-developed have been six appeals of manure storage strategy for identifying these facilities, nor permits—all from members of the public in did it have a formal approval policy in place. opposition to the granting of the permit. Manitoba Conservation has since received The appeal is reviewed by a panel chaired approval to hire additional staff to assist by the Manager of the Environmental in the registration of these facilities and Livestock Section and includes a Manitoba has developed a formal approval process. Conservation professional engineer who Subsequent to their registration, these is familiar with livestock (but was not facilities will require ongoing inspection or involved in the application under review), decommissioning. and Water Stewardship representatives with groundwater and surface water expertise. In Comment a report that goes to the minister, the panel The Commission is of the opinion determines if the regulation and procedures that Manitoba Conservation’s criteria for have been properly applied and whether the siting and construction of manure- there are grounds for appeal. The minister’s storage facilities are adequate to ensure decision on the appeal requires cabinet that these facilities do not pose a threat concurrence. to the environmental sustainability of the Manitoba hog-production industry. Given the The registration of non-permitted significance of the role that soil permeability manure-storage facilities plays in protecting the environment, the In 2004, the Manitoba government Commissions stresses that it is essential that required producers with non-permitted in approving the design for a manure storage storage facilities to register their storage facility, Manitoba Conservation ensure that facilities with Manitoba Conservation by there has been sufficient soil sampling and 2010. Currently the Manitoba government analysis to confirm soil permeability. The has received 416 applications from livestock Auditor General’s report noted that in the operators for the registration of manure- 26 files that it reviewed one proponent storage facilities. Of these applications, 297 never submitted soil test results, one did are for hog-manure-storage facilities. As not submit them until after the facility was part of the registration process, Manitoba put into use, and four did not meet the Conservation can require an examination minimum density requirements. of the facility’s integrity and proximity to The Commission does believe that surface water, surface watercourses, wells, there is a need for ongoing improvement

106 Environmental Sustainability and Hog Production in Manitoba in a number of areas: containment systems time, flow rate calculations, and emergency to provide protection against spills; procedures. maintenance and operation; inspection; and Illinois is currently the only Canadian research into migration through the soils of or U.S. jurisdiction that requires the seepage from manure-storage facilities. certification of manure-storage facility operators. Livestock facilities with under 300 Containment systems animal units are required to have at least While such events are not common, one person certified in waste management above-ground steel and concrete storage handling. A livestock waste handling structures may be subject to catastrophic facility serving 300 or greater animal failure with a resulting contamination of the units is required to operate only under the adjacent area. Given that these structures supervision of a certified livestock manager. are usually sited in sensitive areas where surface and groundwater supplies may be Inspection contaminated, it is appropriate to require The Commission is also of the opinion that they include dyked liquid-containment that there is a need for additional expertise areas with capacity equal to 110 percent of in the inspection of above-ground concrete the capacity of the storage structure. This and steel manure-storage facilities. Aside would be similar to the requirement for from undergoing annual inspection by containment dykes around above-ground Manitoba Conservation staff, these facilities petroleum storage facilities. should be inspected every three years by a qualified structural engineer. Maintenance and operation Maintenance and operation are of equal Migration of contaminants through soil importance as design and siting in ensuring to an aquifer the environmental sustainability of manure- Even with a five-metre soil thickness storage facilities. Facilities are subject to between the floor of a manure-storage a number of potential problems, which structure and an aquifer, seepage from a generally intensify over time. These include manure-storage facility can reach the aquifer damage to liners, propensity for spills during over an extended period of time (McMillan manure handling and transfer, erosion of et al. 2001). The biggest concern is nitrogen the compacted liner, animals burrowing in seeping through to the groundwater. How berms, tree growth in berms, and inadequate long it will take for contaminants to reach freeboard (the distance between the top of an underlying aquifer and in what form the the manure and the top of the surrounding contaminants will be when they do reach the berm) (Richard and Hinrichs 2002). aquifer are important questions that require Given the importance of long-term further investigation. maintenance and integrity of manure- storage facilities, there should be a Technical Reference Manual for Liquid certification process for operators of Manure Storage Structures manure-storage facilities that is similar to Manitoba Conservation has produced the current Manitoba Water and Wastewater the Technical Reference Manual for Liquid Facility Operators Regulation under The Manure Storage Structures as a minimum Environment Act. The manure storage engineering guideline for the design and certification would be similar to the construction of liquid manure-storage Wastewater Class 1 certification and include facilities. The Livestock Manure and knowledge in areas of lagoon operation, Mortalities Management Regulation should odour control, testing/sampling, detention require compliance with the provisions of

107 Manitoba Clean Environment Commission the Technical Reference Manual for Liquid 9.1.3 Administration and enforcement Manure Storage Structures. of the LMMMR

Recommendations Administration Manitoba Conservation is charged with, 9.15 The Manitoba government require among other responsibilities, enforcing that, where new above-ground steel or the LMMMR. The Environmental Livestock concrete storage facilities are located, Team has a total of 19 staff positions dyking be constructed to provide a assigned to it. The Livestock Section in the secondary containment area equal to Environmental Services Branch consists 110 per cent of the capacity of the of five staff: a manager, a professional structure. engineer, a professional agrologist, and two Environment Officers. This office develops 9.16 The Manitoba government require policies and procedures, coordinates delivery certification of manure-storage of services, administers manure management facilities operators, similar to the Water plans and source water monitoring, and and Wastewater Facility Operators coordinates Conservation input into TRC certification. As with Water and Waste reports. Facility Operators, certification should Field delivery of the program is carried be valid for five years. out by Regional Operations Division. There are 14 regional staff with a focus on 9.17 Concrete and steel manure-storage livestock. These include three professional structures be inspected every three engineers and 11 Environment Officers. years by a qualified structural engineer. They process applications for permits, conduct inspections, respond to spills and 9.18 The Manitoba government facilitate, complaints, and provide enforcement. encourage, and undertake further A total of eight staff (five in Eastern studies with respect to migration of Manitoba, three in Central Manitoba, and liquid manure seeping through the earth two in Western Manitoba) are assigned to towards an aquifer and the resulting inspections. In 2006, they were assisted long-term effect on groundwater by two staff, whose primary focus was the supplies. registering of facilities constructed prior to 1994 that do not have permits. An 9.19 The Livestock Manure and Mortalities additional two staff positions have been Regulation require compliance with the created since 2006, whose primary focus is provisions of the Technical Reference registering of facilities without permits. In Manual for Liquid Manure Storage recent years, there has been considerable Structures. staff turnover: as of the fall of 2007, 15 of the 19 positions were filled. 9.20 The Manitoba government report all significant manure-storage facility Inspection design changes to the appropriate Manitoba Conservation Environment municipal authorities. Officers conduct periodic inspections of all permitted manure-storage facilities. As noted above, there are 675 permitted manure-storage facilities in Manitoba. Hog-production operations operate 540 of these facilities, while mixed hog and other livestock operations operate nine more

108 Environmental Sustainability and Hog Production in Manitoba facilities. In the years immediately following time period in which to take measures construction, manure-storage systems are to bring them into compliance. The inspected regularly. They are then generally warning also indicates a date on which inspected on a risk-based assessment, but the operation will be re-inspected. If not less than once every three years. The the operation is in compliance upon re- earthen storage facilities are inspected when inspection, no further action is taken. they are empty: with attention being paid If the operation is not in compliance, to berm maintenance, rodent damage, berm the province may issue a director’s slumping and rutting, erosion at the base, order, an offence notice, or commence a spillways and inlets, condition of ramps, and prosecution. the auditing of monitoring wells. Above- ground tanks are inspected when they are 2) Environment Officer Order. In situations full, with attention being paid to overflow, where there are or are likely to be spillage, seepage or leakage, corrosion, rust, unsafe conditions or irreparable damage stress marks, condition of sump pumps, and to the environment or an imminent monitoring wells. In 2005, 135 inspections threat to environmental health, an of permitted manure-storage facilities Environment Officer may issue a written were conducted. In 2006, 662 inspections order to a producer to cease or modify of permitted manure-storage facilities operations. While this order expires were conducted. The inspection of all the after five days, the Director (Manitoba permitted facilities identified a significant Conservation) has the authority to number of maintenance issues leading to renew it. an increase in facility repairs. The current 3) Director’s Order under The Environment goal is to inspect all operations annually, Act. In situations where there are or with a focus on the higher risk facilities. are likely to be unsafe conditions or The Auditor General’s report concluded irreparable damage to the environment that Conservation was not carrying out or an imminent threat to environmental inspections in a manner consistent with a health, under the power of The risk-based approach. The Auditor General Environment Act, the Director (Manitoba recommended that the inspections take a Conservation) can issue a written broader approach to inspection, monitoring order to a producer to cease or modify compliance with all elements of the LMMMR operations, clean or repair the area and municipal conditions on livestock affected, or restore the environment to operations, as well as inspection of the a satisfactory condition. The Director manure-storage facility. can specify the time period in which the order will be in effect. Enforcement In enforcing the regulations, Manitoba 4) Director’s Order under The Dangerous Conservation takes the position that Goods Handling and Transportation compliance is mandatory and that the Act. Under The Dangerous Goods regulations are to be applied with an Handling and Transportation Act, the emphasis on preventing damage to the Director (Manitoba Conservation) has environment and environmental health. authority to issue a range of orders Enforcement options available to Manitoba regarding the handling and disposal Conservation are: of dangerous goods and contaminants. 1) Warning. This is a written notice that If a Director’s order issued under The an operator is not in strict compliance Dangerous Goods Handling and Transport with the law. The operator is given a set Act is not carried out, the Director can require that the activity be undertaken

109 Manitoba Clean Environment Commission by the department and issue an order the court may suspend or revoke all for payment of costs. relevant provincial licences or permits.

Table 9.7 outlines the number of Depending on a number of factors, different types of sanctions that have been including the severity of the violation and employed from 1994-1995 to 2005-2006. the history of the operator, the province Table 9.8 outlines the number of Director’s can choose between two courses of legal orders that were given since 1998. It should action when addressing operators who be borne in mind that these enforcement violate environmental laws, regulations, and actions apply to more than the hog sector. orders. These are to either issue an offence Table 9.9 gives an overview of the sorts of notice under The Summary Convictions Act issues that Director’s Orders have addressed or to prosecute the operator under either from 1998 to January 2007. The Environment Act or The Dangerous Goods Handling and Transportation Act. Manure spills 5) Offence Notice under The Summary Manure spills from storage facilities are Convictions Act. Environment Officers to be reported if they involve discharge can issue offence notices under The of a total volume of 10,000 litres of liquid Summary Convictions Act to operators manure or more, manure escapes from the who are in violation of the LMMMR. boundary of the agricultural operation, These carry set fines: $557 for individual or manure discharged into a surface and $2,107 for corporations. watercourse, sinkhole, spring or well. If an operator voluntarily reports a manure 6) Prosecution under The Environment spill Manitoba Conservation follows up Act or The Dangerous Goods Handling with a site inspection, issues a clean-up and Transportation Act. Individuals order (if necessary), and notifies Manitoba could be prosecuted for being in Water Stewardship if the spill enters a violation of these acts and their surface water body. If the department is regulations, including orders issued notified of a spill by a third-party, Manitoba under the acts. Conservation also examines the issue to The penalties for individuals are: determine if prosecution is warranted. Table 9.10 outlines the number of known manure a) For a first offence: a fine of not more spills in Manitoba since 2003. than $50,000, imprisonment for not The two largest spills occurred in 2004: more than six months, or both. • 5.0-million-litre spill when a pipeline b) For subsequent offences: a fine of not ruptured. more than $100,000, imprisonment • 4.7-million-litre spill caused by for not more than one year, or both. rainwater on cover. In addition, the court may suspend or revoke all relevant provincial licences or The third largest spill was 2.3-million- permits. litre spill in 2003 when a steel tank failed.

The penalties for corporations are: Manure management plans Approximately 500 manure management a) For a first offence: a fine of not more plans are registered with Manitoba than $500,000. Conservation each year. It attempts to audit b) For each subsequent offence, to a fine of ten per cent of these annually, selecting not more than $1,000,000. In addition, them on the basis of the soil test results

110 Environmental Sustainability and Hog Production in Manitoba

Table 9.7: Sanctions 1994-95 to 2005-06.

Fiscal Year Prosecutions Warnings Orders Totals Fines 1994-95 5 15 1 21 1,188.00 1995-96 8 13 1 22 1,716.00 1996-97 14 21 4 39 11,010.00 1997-98 15 12 6 33 6,726.00 1998-99 12 32 7 51 11,862.00 1999-00 9 35 10 54 8,496.00 2000-01 16 49 22 87 8,067.00 2001-02 16 53 34 103 11,903.00 2002-03 15 59 21 95 20,280.00 2003-04 19 54 57 130 23,076.00 2004-05 16 63 45 124 36,960.00 2005-06 12 53 35 100 8,935.00 TOTALS 157 459 243 859 150,219.00

Source: Manitoba Conservation.

Table 9.8: Director’s Orders, 1998 to Jan 2007.

Central (Interlake and Northeast Northwest Eastern Western Red River Valley Engineering assessment 0 0 1 12 56 or investigation of a manure-storage facility or confined livestock areas Remediation/ clean up 0 0 0 5 4 Decommission manure- 0 0 0 3 1 storage facility Repair of manure- 0 0 0 12 2 storage facility Removal of manure 0 0 0 0 6 Mortality disposal 0 1 0 11 2 Cost recovery 0 0 0 -- 0

Source: Manitoba Conservation.

111 Manitoba Clean Environment Commission

Table 9.9: Livestock Manure and Mortalities Management Regulation: Total enforcement actions 1994-1995 to 2005- 2006.

1994- 1995- 1996- 1997- 1998- 1999- 2000- 2001- 2002- 2003- 2004- 2005- 95 96 97 98 99 2000 01 02 03 04 05 06 Improper 7 9 9 7 11 12 14 28 18 31 46 25 management of mortalities

Manure escapes/ 11 9 11 15 12 12 5 13 6 11 15 12 spills

Operator -- -- 9 1 3 5 10 13 4 12 11 12 confined livestock area in manner which causes pollution Fail to operate -- -- 4 4 8 5 27 24 16 31 12 20 manure-storage facility in manner that does not cause pollution

Section 6 of ------15 13 13 13 11 11 11 12 the LMMMR violations* Manure ------4 12 12 40 22 20 13 Management Plan Violations

Other 3 4 6 6 2 3 6 -- -- 12 9 6

*Section 6 violations include: no permit, no approval, no engineer’s certificates, failure to comply with terms of permit, failure to submit water analysis reports. Manure management plan violations include failing to file plan, winter spreading, not applying in accordance to plan, to manure management plan, exceeding application limits, and failure to submit soil tests. Source: Manitoba Conservation.

prior to application, the recommendations Table 9.10: Manure spills in Manitoba. of regional staff, complaints of excessive application, and random selection. All Year Spills Major spills audits involve field visits and soil tests to 2003 23 2 determine compliance with the LMMMR. 2004 23 4 Table 9.11 sets out the growth in the 2005 20 0 number of plans registered with Manitoba Conservation and the number of plans that 2006 18 3 are audited annually. The Auditor General’s Total 84 9 report identified a number of shortcomings in the assessment of these plans, including Source: Manitoba Conservation. missing information and soil samples from fields that did not match the fields that had

112 Environmental Sustainability and Hog Production in Manitoba been identified in the manure management The Commission notes that the staffing plan. Of more significant concern is the fact rates for enforcement have increased that the Auditor General estimated that significantly in recent years. It is also operations that are obliged to register plans the case that the industry has expanded are not doing so. Of the 24 operations that dramatically during this period. As the the Auditor General examined that were manure-storage facilities that were put into supposed to file plans, six were not doing operation in the past decade age, there will so. The Auditor General also concluded be a need for increased monitoring and that the audits of manure management communication with operators. Therefore, it plans were narrow in scope and the audit is important that the government ensures results were not adequately communicated that sufficient staff and resources are to operators. In its response to the audit, available for necessary inspection and follow Manitoba Conservation indicated that it had up. since established the position of Manure Management Planning Coordinator and was Recommendations addressing these issues. The Commission notes that fewer than 9.21 The Manitoba government continue its half of Manitoba hog producers are currently policy of having Manitoba Conservation registering manure management plans. These Environment Officers inspect all licensed plans are key documents for the sustainable manure-storage facilities on an annual management of manure. For this reason, the basis with a priority being given to the Commission will be recommending that all high-risk operations. new, modified, or expanding Manitoba hog- producers be required to register manure 9.22 The Manitoba government require all management plans. new, modified, or expanding hog- production operations to register manure Table 9.11: Manure management plans management plans. registered and audited 2001-2006 9.23 The Manitoba government ensure that Manure Manure management plans management plans Manitoba Conservation has sufficient Crop Year registered audited resources to assess proposed hog- 2001 236 15 production operations, inspect existing operations on an annual basis, audit 2002 284 0 10 per cent of manure management 2003 336 56 plans annually, register non-permitted 2004 357 8* manure-storage facilities, and 2005** 458 46 enforce existing manure-management 2006 488 33 regulations.

* The 2004 audit was suspended in the early stages because of a change in regulatory requirements 9.2 Water use pertaining to nitrate nitrogen. As noted in Chapter 6, hog-production ** Prior to 2005, operations with 400 animal units operations require water for hogs to or more were required to file manure management drink, for maintenance, and to flush plans. From 2005 onward, operations with 300 or more animal units were required to file manure management manure to storage systems (in the case plans. of operations that use liquefied manure Source: Manitoba Conservation. storage systems). This water use can be a barrier to sustainability if it threatens local or regional water supplies or if excess water use exacerbates the cost of

113 Manitoba Clean Environment Commission transporting manure and contributes to There are similar questions that have imbalances in the nitrogen-to-phosphorus to be addressed in the licensing of surface ratio in manure. While the Commission consumption. has concluded that the current rate of Terms and conditions of a water rights water use by the hog-production industry licence are developed on a site-by-site basis is likely environmentally sustainable, the but typically can include: Commission believes that the Manitoba • Limitation on specific uses for the government needs to further develop its water. For livestock, the annual water-use monitoring in order to ensure allocation is determined by the size and long-term sustainability of the resource. type of livestock operation. Matching 9.2.1 Water allocation to hog producers the allocation in this way is viewed as a barrier to waste. Water is a provincial Crown resource. Under The Water Rights Act (1980), all • Limitations on the total volume of water water use, except for domestic purposes, that may be withdrawn. requires either a licence or authorization from the Water Stewardship Department. • Limits on the maximum depth to water The provincial government allocates in the aquifer, below which further water for beneficial use without wastage. groundwater withdrawals cannot occur. Beneficial uses are defined as Domestic use, Municipal use, Industrial use, Agriculture • A requirement that the licensee must use, Irrigation, and Other purposes (such as correct any problems with the existing aquaculture, fire protection, and recreation). water supplies that are attributable to Manitoba’s 1,200 hog-production operations the withdrawal of water authorized by have water allocated to them in one of two the license. ways: either as a part of their domestic • A requirement for a water measuring allocation or through a water rights licence device that will accurately measure flow that has been issued for agricultural use. and volume of water withdrawn. Applicants for a water rights licence must identify the intended use, the annual Licences cost $50, are issued for a period withdrawals and the flow rates, construct of time to a maximum of 20 years, and may preliminary works, and conduct a series of be renewed upon application. tests and analyses. The proponent may be While all holders of water rights required to submit a project assessment that licences are required to report their water addresses the following questions. consumption on an annual basis, the province does not record or aggregate these • Can a well or wells of sufficient capacity readings to ensure that operators are not be developed to provide the required exceeding their licensed amount. Manitoba water supply? Water Stewardship does check the meter • Will the groundwater for this project when an operation is expanding or changing result in negative impacts to other ownership and reports that, in almost all groundwater users in the area in either cases, the amount of water used conforms to the short or long term? the licence.

• Can the aquifer sustain the required Domestic use supply without depleting the Domestic use means the use of water groundwater resource or causing a obtained from a source other than a deleterious environmental effect over municipal or community water distribution the long term? system, at a rate of not more than 25,000

114 Environmental Sustainability and Hog Production in Manitoba litres per day, for household and sanitary account for approximately 80 per cent of the purposes, for the watering of lawns and licences (approximately 270 licences). The gardens, and the watering of livestock Manitoba Pork Council told the Commission and poultry. There is no requirement for that, based on Manitoba Water Stewardship a licence or the metering, reporting, or records, 4,440 cubic decametres of recording of the level of water use. groundwater had been allocated to the hog industry under 215 water rights licences. Agricultural purposes water rights This figure excluded groundwater allocated licence to mixed-use sites (sites with both domestic One of the categories of water rights and general livestock uses) and surface licence is a license for Agricultural purposes. water resources specifically allocated to hog Manitoba Water Stewardship defines production (which the Council stated to be agricultural purposes as the use of water at a minor component of the total volume). a rate of more than 25,000 litres per day These figures suggest that between 215 for the production of primary agricultural and 270 Manitoba hog producers have products, but does not include the use of been allocated water rights licences. If water for irrigation purposes. In reality, this is correct, approximately 1,000 of the the water allocated under these rights is province’s 1,280 producers provide for the used by livestock operations. The Manitoba animals’ water needs under their domestic government grants two types of Agriculture allocation. water rights licence: one for withdrawal of surface water and one for the withdrawal of Water sources groundwater. While groundwater is an important As of October 2007, there were 342 source of water for the hog-production valid Agriculture water rights licences (307 industry, water may also be obtained from groundwater licenses and 35 surface water regional pipelines and surface water sources. licenses.) Table 9.12 outlines the number of The industry often uses small, untapped licenses that have been granted for livestock aquifers and intermittent streams. In the operations from 2001-2006. Red River Valley, where water can be hard to come by, licences have been issued to Table 9.12: Livestock water rights licensing hog operations that pump water during activity 2001-2006. the spring runoff period from the drainage Surface Water channels. Year Licences Groundwater Licences 9.2.2 Water consumption 2001 2 58 A report prepared for the Commission 2002 4 32 stated “any attempt to estimate water 2003 4 5 usage by Manitoba hog operations is a 2004 1 34 daunting task given the lack of sufficient 2005 4 44 information” (Nyachoti et al. 2007, 107). Manitoba Water Stewardship’s policy of 2006 4 53 not recording the reported meter readings, Total 19 226 coupled with the large number of operators that are not licensed, makes it difficult to Source: Manitoba Water Stewardship. get a firm grasp on the amount of water the hog-production sector consumes. Manitoba Water Stewardship does not keep a tally of the number of hog operations that have received water rights licences. However, it estimates that hog producers

115 Manitoba Clean Environment Commission Calculations based on water licenses Table 9.13: Total water usage by hog Manitoba Water Stewardship has inventories in Manitoba, April 1, 2007. allocated 8,220 cubic decametres of Hog type Water usage groundwater for Agriculture Purposes. This Number of hogs (litres per day) amounts to 7.3 per cent of total groundwater Breeding stock 372,700 9,895,185 allocations. It has also allocated 1,334 cubic decametres of surface water for Agriculture Nursery 1,110,800 4,221,040 Purposes. This amounts to 0.3 per cent of Grow-Finish 1,436,500 16,807,050 surface water allocations. Total 2,920,000 30,923,275 The 9,554 cubic decameter figure represents the amount of water allocated Source: Nyachoti et al. 2007. to the agriculture sector, it is not a report The figure of 30,923,275 litres a day on the amount of water used. Furthermore, converts to 30,923 cubic meters a day or it does not include the amount of water 30.9 decametres a day or 11,278.5 cubic that is used to produce hogs by those hog- decametres a year. This figure is nearly production operations using water from their three times the amount that the Manitoba domestic allocation. While there are a large Pork Council estimates to be allocated to number of such operations, they are likely to the industry and also higher than the total account for a small portion of production. amount that Manitoba Water Stewardship In 1987, the Manitoba government states is allocated for agricultural purposes, began levying fees for users who are which includes all specifically licensed licensed under the Industrial and Other Use livestock and poultry operations. Given the categories. The purpose of the fees was to fact that Manitoba Water Stewardship does make major users more aware of their rate of not have data on water use, as opposed to consumption and to encourage conservation. allocation, it is difficult to determine if the It is estimated that there are 2.9- resource is being managed to maximize its million hogs in Manitoba at any one time: sustainability. 372,700 breeding stock, 1.1-million nursery There is a need for Manitoba Conservation, hogs, and 1.4-million grower/finisher hogs. Water Stewardship, and the industry to work Given that there are estimates for water together to determine an accurate volume use per hog, it is possible to estimate water of water used by the industry. This should use based on these numbers. There is an include the following: important caveat that needs to be placed on such an estimate, namely that the water- • Reading of meters by Manitoba use estimates are subject to considerable Conservation at the time of annual variability due to the differences between inspections. operations. The same variability applies to estimates as to the amount of water needed • Comparison of meter readings with for cleaning and flushing of barns. A paper allocated amounts for a period of time prepared for the Commission used water-use to be determined. estimates to produce the summary of the • Research into the use of water by total daily water usage of Manitoba hogs function. found in Table 9.13. • Amount of water used by small operations for purposes of hog raising.

• Amount of licensed water used by large mixed farms specifically for their hog operations.

116 Environmental Sustainability and Hog Production in Manitoba

Once the foregoing information is reduce and control water use. Therefore, available, a reliable understanding of the at this point, the Commission is not volume used by the industry by function can recommending that any additional water-use be determined. This information can then fees be contemplated. be used to maximize the efficiency of water use. Comment The Commission recognizes the need Reducing water use to conserve and protect water quality and There are a number of management quantity and the legitimacy of using water practices that can be adopted to reduce as a factor of production in a sustainable water usage in the hog-production industry. manner. The Commission also supports the These include: goals of Manitoba’s 2003 Water Strategy, • The amount and composition of the hog which emphasize watershed planning, diet. benchmarks for sustainable withdrawals, and the potential of demand management. • The design and construction of the units The Commission is satisfied that Water from which hogs drink (drinkers). Stewardship undertakes the appropriate work in determining whether or not to • Animal management (bored and closely grant a water licence to a hog-production confined hogs drink more). operation. Furthermore, the Commission notes that the livestock sector is assigned • Recovery and recycling of wastewater. 7.3 per cent of total groundwater • Technologies that move waste with less allocations, 0.3 per cent of surface water water. allocations, and 1.3 per cent of total water allocations. The Commission further • Solid manure housing systems (in which recognizes that the need to dispose of the the solid manure is not liquefied). liquefied manure provides producers with an According to the study prepared for the incentive to control water usage. Commission, some of these approaches are These observations are balanced by the still in development stages and may not be Commission’s concern over the lack of strong economically viable. In other cases, there data as to the amount of water that the is little data on the degree to which new livestock sector consumes. Future policy and technologies have been adopted (Nyachoti et planning will require stronger data on water al. 2007). use. While it would appear water resources One method of reducing use is demand are being managed in a sustainable manner, management through price increases. The the Commission believes that stronger cost of water varies in many jurisdictions data are required before a more confident in Manitoba, and good arguments can be assertion can be made about the sector’s made that, in some locations, increases in sustainability. the price of water could provide a greater incentive to conservation. However, the Recommendations intensive hog-production industry must 9.24 The Manitoba government obtain shoulder the cost of storing the water after accurate data on livestock water use in the form of liquid manure and then sources, quality, and usage. This of applying the water to the land. From would include the reading of meters the disposal perspective, if the operation at livestock operations by Manitoba is complying with all existing manure and Conservation Environment Officers at the nutrient management regulations, there time of inspection of manure-storage exists a considerable economic incentive to

117 Manitoba Clean Environment Commission facilities, the comparison of meter readings with allocated amounts, and the publication of annual summaries of use versus allocation for each sector.

9.25 The Manitoba government compile information on technologies that reduce water usage without compromising animal performance and make this information available to producers.

9.26 The Manitoba government facilitate, encourage, and undertake further studies into water use, water wastage, and water use reduction technologies and practices. This should include:

• The use of water by genotype, production phase, environment and health status.

• The amount of water used by unmetered operations engaged in hog production.

• Animal management strategies and animal housing designs that minimize water usage and wastage and therefore reduce manure volume.

• Waste water recycling for existing operations that may not be able to significantly reduce water use because of design.

• Hog rations that minimize excess nutrients and mineral intake, thus influencing water intake as well as manure output.

118 10 Air quality

he Commission has identified two In 2005, it was estimated that Canada’s potential environmental sustainability greenhouse-gas emissions were 747,000 Tissues relating to the emissions that come kilotonnes of carbon dioxide equivalency, from hog-production: climate change and while Manitoba’s emissions were 20,300 odour. kilotonnes of carbon dioxide equivalency (2.1 per cent of the national total). On the 10.1 Climate Change national level, agriculture contributed 57,000 Agriculture produces three main kilotonnes of carbon dioxide equivalency greenhouse gases: carbon dioxide, methane, (8 per cent of the national total). Manitoba and nitrous oxide. While carbon dioxide is the agriculture contributed 6,000 kilotonnes of most common greenhouse gas, it is not the carbon dioxide equivalency (0.8 per cent of most potent. Methane is 21 times more potent the national total). than carbon dioxide, while nitrous oxide is 310 Livestock-related greenhouse-gas times more potent. It is common to convert emissions represent approximately 68.2 all emissions to carbon dioxide equivalents for per cent of total emissions from Manitoba ease of comparison. agriculture. There are four livestock-

119 Manitoba Clean Environment Commission related agricultural sources of greenhouse to Manitoba Agriculture, Food and Rural gases in Manitoba: enteric fermentation Initiatives (MAFRI) calculations, in 2005, (fermentation taking place in the intestinal hog production in Manitoba was responsible system), manure management, manure for approximately 6 to 8 per cent of the applied as fertilizer, and manure deposited greenhouse-gas emissions from Manitoba on pasture land. Table 10.1 provides a break agriculture. down of the source of livestock greenhouse- While the hog industry is not a major gas emissions in Manitoba. contributor to climate change, the industry’s contribution can be reduced by the use of Table 10. 1: Manitoba greenhouse-gas synthetic covers on manure-storage facilities emissions related to livestock. and the injection or incorporation of manure Per cent of when it is applied to land. These methods total Manitoba not only reduce greenhouse-gas emissions agriculture by 40 to 80 per cent, they can improve the greenhouse- nitrogen to phosphorus ratio in manure Source of emission Greenhouse gas gas emissions (both in storage and in application), reduce Enteric Methane 41.5 the risk of nitrogen and phosphorus loss, fermentation and reduce odour concerns. (See Table Manure Methane 15.9 10.2 for estimates of the nitrogen losses to management and nitrous oxide the atmosphere associated with different application methods.) For all these reasons, Manure applied Nitrous 3.2 as fertilizer oxide the Commission is recommending that new operations be required to utilize synthetic Manure on Nitrous 7.6 pasture oxide covers and inject or incorporate manure within 48 hours. The Commission recognizes Total 68.2 that in order to meet the conditions of Source: National Inventory Report 1990- the coming ban on winter application 2005 – Greenhouse Gases and Sinks in Canada many smaller operators are going to have (Environment Canada, 2007). to construct manure-storage facilities. The Enteric fermentation from cattle (dairy Commission believes that the Manitoba and non-dairy) accounts for the greater government has a responsibility to these part of the all agriculture greenhouse producers to assist in the construction of gas emissions at approximately 39 per these facilities, assuring that they have cent (hogs account for approximately 4 appropriate covers. per cent of the enteric emissions from Recommendation Manitoba agriculture or 1.5 per cent of the total greenhouse gas emissions 10.1 The Manitoba government require that from agriculture). The major hog-related all new manure-storage facilities have greenhouse-gas emissions are calculated synthetic covers (ideally negative under the manure-management category. pressure covers). Hogs account for approximately 33 per cent of emissions related to manure management 10.2 The Manitoba government require all (approximately 5 per cent of the overall new and expanding operations to either emissions from Manitoba agriculture). The inject or incorporate manure, with manure on pasture category in Table 10.1 incorporation taking place within 48 refers to manure deposited by animals hours. that are being fed on pastureland ; hog manure does not account for any significant portion of these emissions. According

120 Environmental Sustainability and Hog Production in Manitoba

Table 10.2: Volatilization losses (%) associated with different application Methods and weather conditions.

Application details Average Cool wet Cool dry Warm wet Warm dry Injected 0% 0% 0% 0% 0% Incorporated 25% 10% 15% 25% 50% within 1 day Incorporated 30% 13% 19% 31% 57% within 2 days Incorporated 35% 15% 22% 38% 65% within 3 days Incorporated 40% 17% 26% 44% 72% within 4 days Incorporated 45% 20% 30% 50% 80% within 5 days Not incorporated 66% 40% 50% 75% 100% Irrigated Above +10% Above +10% Above +10% Above +10% Above +10% Standing or 35% 25% 25% 40% 50% Cover Crop/ Stubble

Adapted from Tri-Provincial Manure Application and Use Guidelines.

10.2 Odour In its 1979 report on the intensive Odour is one of the major issues that livestock industry in Manitoba, the Clean residents are likely to raise when they are Environment Commission made three informed that a hog-production facility may comments relating to odour. The first be established in their community. While the was that while “some offensive odour Commission only heard a limited number of is normally associated with livestock specific complaints about hog-facility odour, production operations…livestock odours those concerns were clearly heart-felt and can be a substantial nuisance to those not real. People spoke of being confined in their engaged in the production operation.” homes by a wall of odour and being unable The most effective way of addressing this to enjoy their property during the summer. (beyond good housekeeping and effective The odour issue has been at the centre manure management) was “to introduce a of many conflicts relating to the hog considerable separation distance between industry for over three decades. In 1973, livestock operations on the one hand and when the Manitoba government exempted residential or commercial land use on the a Manitoba hog-production facility from other.” While the odour issue is often framed a Clean Environment Commission order to as a conflict between farming and non- reduce the number of hogs on the operation farming rural residents, the Commission and lower the odour emissions, the decision observed that most of the odour complaints was justified with the argument that “came from people who are agricultural “the present state of scientific knowledge producers” (Clean Environment Commission concerning the control of odours from 1979, 5). The Finding Common Ground report livestock operations is insufficient to stated “The challenge facing the Panel was formulate specific limits for odours other to separate largely emotional reactions to than on an arbitrary basis” (Wilson 1975). the nuisance of odours from genuine health

121 Manitoba Clean Environment Commission hazards. We attempted to ‘get a handle’ operating practices. In Manitoba, municipal on the science, but found it an extremely planning takes place in a context developed complex area with woefully inadequate by the provincial government, while the research” (Livestock Stewardship Panel 2000, provincial Farm Practices Protection Board 32). The Panel, for example, questioned is intended to ensure that hog operations why in placing setbacks, municipalities adhere to established farm practices. The rarely exceeded the provisions in the Farm next two sections of this chapter deal with Practices Guidelines. those issues. There are four main potential sources of odour from most intensive hog-production Municipal planning operations: The provincial government is requiring • Building exhaust. municipalities to establish livestock operating policies by 2008. These policies • Manure storage. will outline various zones within a municipality and indicate whether they • Land application. are appropriate for livestock development. • Mortality disposal. This planning measure could play a role in limiting future odour-related issues. Research suggests that mortality Beyond that, at the approval stage, disposal is not an odour problem in rural municipalities have the authority to Manitoba. However, the other three sources require operations to cover their manure- can be problematic. storage facilities, to construct shelter belts and to situate their operations a set 10.2.1 Manitoba regulations distance from residences and designated The two most effective ways to deal areas (urban centres, settlement centres, with odour are through good municipal rural residential, seasonal residential areas, planning and good on-farm maintenance and

Table 10.3: Minimum separation distances for siting livestock operations.

Separation distance in metres (feet) from Separation distance in metres (feet) single residence from designated areas To animal-housing To animal-housing Size of Livestock facility and non- facility and non- Operation in animal To earthen manure- earthen manure- To earthen manure- earthen manure units storage facility storage facility storage facility storage facility 10 – 100 200 (656) 100 (328) 800 (2,625) 530 (1,739) 101 – 200 300 (984) 150 (492) 1200 (3,937) 800 (2,625) 201 – 300 400 (1,312) 200 (656) 1600 (5,249) 1070 (3,511) 301 – 400 450 (1,476) 225 (738) 1800 (5,906) 1200 (3,937) 401 – 800 500 (1,640) 250 (820) 2000 (6,561) 1330 (4,364) 801 – 1,600 600 (1,968) 300 (984) 2400 (7,874) 1600 (5,249) 1,601 – 3,200 700 (2,297) 350 (1,148) 2800 (9,186) 1870 (6,135) 3,201 – 6,400 800 (2,625) 400 (1,312) 3200 (10,499) 2130 (6,988) 6,401 – 12,800 900 (2,953) 450 (1,476) 3600 (11,811) 2400 (7,874) >12,800 1000 (3,281) 500 (1,640) 4000 (13,123) 2670 (8,760

Source: Manitoba Provincial Land Use Policies. 122 Environmental Sustainability and Hog Production in Manitoba parks, recreational areas, existing land uses • 77 per cent of all complaints related to in the area). These setbacks must be at least odour. the minimum distances prescribed in the Provincial Land Use Policy for agriculture. • 65 per cent of all complaints related to The setbacks are set out in Table 10.3. hog odour. The shelterbelts and the setbacks relate • 69 per cent of all hog odour complaints to the location of the barn and manure- led to orders that the operator either storage facility, but do not apply to the modify or cease their practice. This fields on which manure is applied. Coverage amounts to 77 per cent of all orders to of manure storage units relates, obviously, modify or cease practices issued by the only to manure storage. None of these Board. measures control odours when manure is applied to fields or protect residents from There has been a significant drop off those odours. in the number of complaints filed with the Prior to the adoption of The Planning Board: in 2000-2002, 36 complaints were Act in 2005, these separation distances were filed. In 2006, three complaints were filed. recommended in the Manitoba Farm Practices In its orders relating to hog production Guidelines. Municipalities have made it odour, the Board has typically: clear that they wish to retain the authority • Ordered the covering of manure storage- for granting conditional-use permits and facilities (usually with straw). placing conditions that mitigate the odour from livestock operations. However, the • Ordered the planting of shelter belts. Commission has heard from both large • Ordered the incorporation of manure and small municipalities that they lack when it is being applied to fields. the financial resources to enforce their bylaws and from residents who believe their The Board’s record is in many respects councils lack the political will to enforce quite admirable. The following comments their bylaws. In one case, rather than relate not to the way the Board has enforce its own bylaw, a rural municipality conducted its business, but to its legislative filed a complaint with the Farm Practices powers and limited resources. Protection Board. This issue was further The Commission has identified the complicated by recent amendments to The following concerns with the FPPB’s policies Municipal Act that removed residents’ right and authority: to go to the courts to have bylaws enforced. • Complainants are required to deposit $50 when filing a complaint. The $50 Farm Practices Protection Board is returned, unless the FPPB rules that Residents with complaints about odour the issue under complaint arose from from livestock operations can take their a normal farming practice. Over 13 complaints to the Farm Practices Protection years, there have only been seven cases Board (FPPB). The FPPB is charged with where the Board had declined to return determining if the issue arises from a normal the applicant’s $50. The Commission farm practice or not. If it does not arise from believes the deposit is an unnecessary a normal farm practice, the FPPB can issue and illogical deterrent that punishes an order requiring the operator to modify those applicants who were mistaken as the practice. Table 10.4 breaks down the to whether the practice was or was not complaints received by the FPPB by category considered normal. It should be noted and how they were disposed of. that the FPPB has never had to exercise The following points can be made about its right to dismiss cases that it believed the information in Table 10.4. to be frivolous or vexatious.

123 Manitoba Clean Environment Commission • The staff who inspect operations to see time-consuming steps and the Board if FPPB orders are being complied with has not undertaken them to date. In have no order-making powers. Each 2007, some operators who were required year, MAFRI staff inspect operations to cover their earthen manure-storage with orders against them to see if they facilities were unable to do so because are in compliance. This is of particular they could not get access to sufficient significance in the case of operations dry barley straw to provide a full cover required to cover manure-storage for the facility. In these cases, the Board facilities with straw, since the covers sent the operators letters telling them have to be reconstructed each year. that they must conform to Board orders MAFRI staff have no enforcement powers in 2008. Complainants cannot go to and simply prepare reports for the Board court to have a Board order enforced, as to the level of compliance. although they can initiate a nuisance suit after the FPPB has dealt with their • The FPPB has limited ability to enforce complaint. To date, no complainant has its decisions. The Board can file its initiated a nuisance suit. orders with the court and also apply for a court order to have the order complied • The PPB has a relatively low profile. with. These are both cumbersome and Some people may not be aware of its

Table 10.4: Types of complaints received by Farm Practices Review Board and resolution of the complaint.

Dismissed because the operator was Refused to conducting hear because Reconsidered/ Mediated/ activities in a outside Modify further modify Cease Withdrawn normal manner. mandate Pending Noise 0 0 0 1 0 0 0 Dust 1 0 0 0 0 1 0 Spray 3 0 0 1 1 0 0 Smoke (to 4 0 0 1 0 1 protect horses from insects) Wild Boar 0 0 0 1 0 0 0 Odour 32 5 1 7 4 0 0 Hogs Odour 1 0 0 1 1 0 0 Dairy Odour 1 0 0 2 1 0 1 Beef Odour 0 0 0 1 0 0 0 Crop Others 0 0 0 0 0 2 0 42 5 1 15 7 4 1

Source: Manitoba Farm Practices Review Board.

124 Environmental Sustainability and Hog Production in Manitoba

existence. Even when they are aware of covers also reduce nitrogen loss, leading its existence, some people may not be to more efficient nutrient use. fully aware of how the Board operates. For example, the Commission was told • Dietary manipulation. Improvements in by some rural municipalities that the the uptake of phosphorus and nitrogen Board does not accept complaints can reduce the level of nutrients in from municipalities, when, in fact, it manure and reduce odour. does. This could be due to a number • Solid and liquid separation. The of reasons: a prime one would be the separation of solids from liquids in Board’s very modest budget, which manure can make it possible to better makes it difficult for it to undertake control odour. outreach work. • Shelterbelts. The evidence suggests that 10.2.2 Mitigation strategies shelterbelts, which provide numerous There are a number of strategies that other environmental benefits, can can be adopted to reduce odour impacts. provide limited benefit in reducing These include: odours. This has to be balanced with the • Proper ventilation and maintenance of fact that it may take many years before barns. The Commission has reviewed they reach maturity and provide their reports that suggest biofilters can optimum benefit. reduce odour emissions from barns. The Commission notes that no branch of 10.2.3 Information gaps the provincial government appears to A literature review commissioned by the be reviewing the ventilation systems of Commission for this Investigation concluded new or expanding barns before they are that while odours, for the most part, are not constructed, nor are there requirements direct threats to human health, they could that have to be met before a barn is put trigger a variety of health problems. Given into operation. the difficulties in measuring concentrations downwind from hog operations, the • Adequate separation distances. While researchers did not believe that methods odour plumes (the distance at which used for regulating industrial pollutants odour can be detected) may extend were appropriate in regulating the odour beyond the current setback distances, from intensive livestock operations. The at those distances, the odour, while paper identified a number of weaknesses detectable, would be below the nuisance with the Manitoba regime for monitoring level. Manitoba’s setbacks appear to and assessing odour-related issues. In provide at least as much protection as is particular, it concluded that there was a provided in comparable jurisdictions. need for: • Manure-storage covers. Synthetic • Standards and procedures for measuring covers are reported to reduce odour to odour emission from barns and manure almost nil. The impact of straw covers, storage in Manitoba. These should cover while significant is far less effective. the assessment of odour downwind from Furthermore, the straw covers do not livestock operations. always operate at maximum capacity • A dispersion-theory-based guideline, due to a wide range of issues, including integrated with odour-impact models, partial coverage and the eventual should be established in Manitoba. Such submersion of the straw. Synthetic a guideline would give consideration to the various factors that affect odour

125 Manitoba Clean Environment Commission emission and dispersion, including Protection Board under their powers topography and technology. under The Environment Act. The review identified the need for additional information in the following 10.5 The budget of the Farm Practices areas: Protection Board be increased to allow it to undertake more outreach work to • Potential health effects associated with make members of the public aware of its odour downwind from hog operations. services. These are needed to establish suitable acceptability criteria for community 10.6 The Manitoba government establish a level exposure to odour. dispersion-theory-based farm odour • Emission rates and characteristics of guideline. Such a guideline would give odour from hog operations. consideration to the various factors that affect odour emission and dispersion • Downwind distribution of odour and including topography and technology. other air contaminants. 10.7 The Manitoba government facilitate, • Economic analysis of odour mitigation encourage, and collaborate on the technologies for Manitoba conditions research and data collection in the (Zhang et al. 2007). following areas:

Comment • Standards and procedures for measuring odour emission from barns For those who are affected by it, the and manure storage in Manitoba. odour from hog production operations is a very serious problem. As noted above, it • Potential health effects associated may, unless properly mitigated, contribute with odour downwind from hog to a variety of health problems. Properly operations. These are needed to managed, however, it should not be a establish suitable acceptability barrier to the industry’s environmental criteria for community level exposure sustainability. If it is not properly managed, to odour. the industry’s social sustainability will be seriously challenged. The Commission also • Emission rates and characteristics of notes that its recommendation requiring odour from hog operations. synthetic covers for all future manure- storage facilities and to have all new and • Downwind distribution of odour and expanding operations either inject or other air contaminants, incorporate manure will significantly reduce • Economic analysis of odour mitigation the number of future odour complaints. technologies for Manitoba conditions. Recommendations

10.3 The Farm Practices Protection Board cease requiring complainants to place a $50 deposit when they file a complaint.

10.4 Manitoba Conservation Environment Officers be given the authority to enforce orders of the Farm Practices

126 11 Flora and fauna

he Commission has identified two key of agriculture, which seeks to produce large issues in assessing the environmental quantities of uniform commodities, can place Tsustainability of the hog-production increased pressures on biodiversity. The industry in its relation for flora and fauna. two potential biodiversity impacts that the These are: Commission identified are: • Impacts on biodiversity. • The threat to biodiversity that arises when natural habitat is brought into • Health impacts (including worker production to serve as agricultural land on safety and health, animal diseases, and which manure can be applied. antibiotic use). • The impact of increased nutrient levels 11.1 Biodiversity in the soil on environmentally sensitive One of the principles of Sustainable areas. Development stresses “the importance of conserving and enhancing natural eco-systems and other ecological resources.” The expansion

127 Manitoba Clean Environment Commission 11.1.1 Conversion of natural habitat Table 11:1: Agriculture and Agri-food Canada The major impact of the livestock soil classifications. industry globally on biodiversity has arisen Soil class Capability from the conversion of natural habitat into cropland to provide the required feed for Class 1, 2 Capable of sustained and 3 production of common field the expanding livestock sector (Steinfeld crops et al. 2006). The intensification of the Class 4 Marginal for sustained arable hog-production industry of the past fifteen agriculture and should be in years has not led to a significant increase permanent forage production in cropland in Manitoba. Indeed, one of the Class 5 Suitable only for improved main reasons for the expansion was to find permanent pasture a market for grain that was already being Class 6 Capable only for native pasture grown in the province but could not be use economically exported. Many hogs are now Class 7 Incapable of use for arable raised in operations that are exclusively agriculture or permanent devoted to hog production. In addition, pasture most large-scale producers store their Source: MAFRI. manure in liquid as opposed to solid form. For these operators there can be a need to Because there is so little undeveloped have access to additional agricultural land Class 1, 2, or 3 soils left in Manitoba, on which to apply the manure that is a by- producers have been putting natural habitat product of hog production. or undeveloped land into crop production to The issue of the lack of access to land increase the available spread acres. In other is intensified by the trend in intensive cases, they might spread manure on pasture livestock production for production or forage land that traditionally would only operations to cluster in specific regions. receive synthetic fertilizers on a limited For example, in Manitoba, where feed basis. companies have played a role in developing The clearing of woodlands, draining the industry, the industry has become wetlands, and changing the character of geographically clustered. This allows for the soils and grasslands has a direct effect considerable control of costs, but can also on the species living in these habitats and increase the need to put marginal lands into on the surrounding area. In many cases, production to provide the needed spread these marginal areas are the last refuge acres. for wild flora and fauna, since few wildlife The Canada Land Inventory, as species can survive on cultivated fields. The administered by Agriculture and Agri- margins that are available to them, such as foods Canada, has developed a national soil fencerows, field margins, missed corners and classification system that classifies land by old farmsteads, are becoming increasingly its agricultural capability (Table 11.1). Lands rare as farm equipment becomes more capable of sustained production of common efficient. These habitats are essential to the field crops are categorized as either Class 1, maintenance of biodiversity in a local area 2, or 3. It is generally accepted that all the (McLaughlin and Mineau 1995). Class 1, 2, and 3 lands available in Manitoba For these reasons, the Commission are already in agricultural production, for is of the view that these lands should the most part in annual crop production. not be brought into production to serve This means that if more land is to be as potential fields for the application of brought into production, it will be on the manure. The long-term agronomic benefit marginal soils of Classes 4, 5, and 6. These of applying manure to this land is still in soils are usually shallow and/or permeable.

128 Environmental Sustainability and Hog Production in Manitoba question, while the potential environmental (McLaughlin and Mineau 1995; Wilson and risks may be significant. Belcher 1989). One of the weaknesses with the current Many of these sites in agro-Manitoba approval and permitting process is that there are also critical to or are the only remaining is no analysis done of a proposed project’s habitats for some of the species listed under potential impact on the local ecosystem The Endangered Species Act, while other or regional biodiversity. There is no areas are of special concern due to their examination of, for example, the ecological declining populations and distributions. implications of converting natural lands Recently, attention has been drawn to or wetlands to fields for the application significant declines in common North of manure, locally or downstream. The American bird species largely due to the loss Commission is of the opinion that the or fragmentation of their habitats (Manitoba Manitoba government should include Conservation- Conservation Data Centre n.d.; biodiversity considerations into its decision- Audubon n.d.). making process both in regard to expansion There has been long-standing in the livestock sector and significant cooperation on the part of many producers changes in land use. By considering these to use or modify their farming methods issues, it may be possible to reduce future (for example, by the adoption of rotational nuisance problems such as crop depredation grazing) to conserve these resources while and regional loss of biodiversity as a result continuing to produce. In these systems, the of habitat loss or fragmentation. cattle replace the role native bison played in the prairie landscape. Nutrients are recycled 11.1.2 The impact of increased nutrient through the cattle and are taken up by the levels in environmentally sensitive growing vegetation. Since no additional areas nutrients are added, the system remains in In addition to the biodiversity impacts balance. that result from changes in land use, the The addition of outside nutrients, Commission is also concerned about changes either synthetic fertilizer or hog manure, that can arise from increased nutrient will certainly increase the productivity levels in the soil. Such increases in a region of the vegetation, but it will also favour can have an effect on biodiversity. The those species that can take up nutrients, plant growth that is native to much of the particularly nitrogen, quickly and select Canadian prairie can survive with limited against the less adaptable native flora. access to available nitrogen and phosphorus. The impacts of this are two-pronged: the Established native grasslands or other vegetation is more productive but the habitats should never be fertilized (although variety of plants and animals that occur is fertilizers may be used to re-establish much reduced. Those that have long adapted native grasslands on disturbed sites). As the to the soil, moisture and climatic conditions nutrient levels increase, weedy species come of the region are often eliminated. Changes to dominate, changing the composition in the nutrient balance will increase the of the eco-system. The changes in plant nutrient runoff, leaching and losses to the composition caused by increases in nitrogen environment. levels have also been linked to increased leaching of nitrogen and a reduction in This is of particular significance for the the sequestration of carbon in the soil and remaining tall grass and mixed grass prairie standing vegetation (Wedin and Tilman sites in Manitoba. For the most part, these 1996). The change in plant composition grasslands have survived simply because also has an impact on the types of wildlife they were rooted on lands that were not that are dependent on native plant life suitable for crop production: the mixed grass

129 Manitoba Clean Environment Commission occurring on sandy soils in the southwest Prairie Preserve. Manure management and the tall grass on stony soils in the plans should distinguish native pastures/ southeast. The Tall Grass Prairie Preserve grasslands from tame pastures/grasslands in the RM of Stuartburn is home to many and application of hog manure to native listed (threatened or endangered) species grasslands or pastures be discouraged. in Manitoba and Canada. This ecological (Native pastures are made up of native community is the last vestige (genetic grassland species, while tame pastures source) of natural tall-grass grasslands that are pastures that have been planted by occurred in the Red River Valley in Manitoba humans.) Special attention should be paid to and is only one of two areas in Canada proposed spread fields that contain natural where it can be found. vegetation, with assessment being given to Increases in nitrogen levels in nearby the effects their conversion may have on pastures and fields could move on to these the local ecology and downstream effects on lands and affect the plant life composition. water management. For example, the recovery plan for the Manitoba Conservation’s Wildlife and Western Prairie Fringed Orchid, which only Ecosystem Protection Branch can play occurs in the Tall Grass Prairie Preserve, an important role in identifying those specifically identifies the application of hog ecologically significant areas that need to be manure to pastures in the area as a possible protected from manure application through threat to this species and the ecosystem in the establishment of buffer zones in which which occurs (Environment Canada, 2006). no application would be allowed. With the application of hog manure on or near these sites, nitrogen may leach or flow Recommendations overland and enrich the soil. This can cause a shift in the species composition and loss of 11.1 The Manitoba government include the genetic bank of the indigenous species, biodiversity conservation considerations including plants and all animals that depend into its decision-making process upon them. regarding the expansion in the livestock In addition to changes on highly sector or significant changes in land vulnerable sites, consideration for alteration use. Policies should identify and respect or conversion of critical habitat for more critical regional wildlife habitats, common species should also be considered. discourage the conversion of natural For instance, conversion of forested or habitats to serve as manure spread brush land that does not appear to hold any fields, and discourage the fertilization of significant ecological value may become native grasslands and prairies. problematic if this site is a traditional deer or elk seasonal-use site and now provides 11.2 The Manitoba government identify feed in the form of a forage field. ecologically sensitive sites (such as tall To address the above concerns, provincial and mixed grass prairie remnants) and and municipal planning processes should establish no-manure-application buffer take into account the impacts of activities zones around them. These zones should on the landscape and on native biodiversity. be established in consultation with eco- Consultations should be undertaken with system specialists and hydrologists on a ecological management specialists to site-by-site basis. identify vulnerable sites and those that should be treated with particular care. Buffer zones, in which no manure fertilizer can be applied, should be established surrounding sites such as the Tall Grass

130 Environmental Sustainability and Hog Production in Manitoba 11.2 Health should be advised, at a minimum, to wear a [National Institute of Occupational Safety 11.2.1 Workplace safety and health in and Health]-approved two-strapped dust the hog industry mask, even if the concentrations of dusts The people who face the most direct and gases are below recommended limits. health risks from the hog-production Persons exposed to [barns] with high dust industry are those who work at the or gas concentrations, or persons with production sites. Aside from the various respiratory conditions, may need to use safety risks that can come from working a more sophisticated respirator such as a with livestock in confined quarters, are the half-mask cartridge respirator or powered health risks associated with the dusts and air-supplying respirator (Donham and Thelin gases that the production process gives rise 2006, 98).” The 2000 Finding Common to. The dusts arise from the animal hair, Ground report reached similar conclusions, dried feces, and feed; the gases from the recommending “All barn workers should be decomposition of urine and feces, fossil strongly encouraged to wear proper masks” fuel heaters, and animal respiration. Key (Livestock Stewardship Panel 2000, 38). elements in controlling these health risks When the Commission inquired about are the ventilation, design, and maintenance the implementation of the policy, it was told of the building. The pathogens described that Manitoba workplace safety and health in Chapter 9 can also represent a potential regulations require employers to assess the health risk to the hog-production workforce. risk to worker safety and health presented The authors of a textbook on agricultural by chemical or biological substances in medicine state that of workers in intensive the workplace. Where the employer cannot livestock industries, hog-production reduce the concentrations of hazardous workers have the most frequent and severe substances to legislated limits through health problems. According to the authors engineering controls such as ventilation, “Prevalence of respiratory symptoms…in the employer must provide workers with nonconfinement swine workers is generally appropriate respiratory protection. Manitoba less than half of that reported by swine Labour and Immigration and Manitoba confinement workers” (Donham and Thelin Agriculture, Food and Rural Initiatives have 2006, 98). In addition, to these issues, also collaborated with the Manitoba Pork hog-production workers are at greater risk Council in the development of educational than members of the general public of being material, including specific recommendations infected by a zoonotic disease (a disease for protection from dust and gases, and that moves from animals to humans). special precautions when working in manure The three best recommended methods of pits. reducing risk involve: The Finding Common Ground report also recommended that “Government, in • Control of dust and gas through conjunction with the industry, should management and engineering. review the in-barn environment with a • Removal of contaminants in the air by view to: establishing a monitoring regime way of the ventilation system. and ensuring compliance with existing regulations, especially those affecting the • Use of personal protective equipment safety and health of workers, assessing such as masks. the training needs of barn workers, and While the first two methods are by far identifying research priorities which bear the most preferable, it should be noted that upon the health of operators, workers and Donham and Thelin concluded: “Anyone the nearby public” (Livestock Stewardship working in a swine or poultry [barns] Panel 2000, 38). In response to inquiries

131 Manitoba Clean Environment Commission about this recommendation, the Commission resolve and greater reliance is placed on was informed that, in 2002-2003, Manitoba personal protective devices such as masks. Labour’s Prevention Services Branch of the Barn-design decisions regarding ventilation Workplace Safety and Health Division, made can also have a significant impact on odour- the hog-production industry one of its focus related issues. Currently in Manitoba, farm industries, inspecting 35 operations in that buildings are exempted from the provisions year. The issues identified varied, depending of the National Farm Building Code. This on the size and age of the operation. In exemption has implications for animal safety some cases, operations were instructed as well as for worker safety. According to to carry out air-quality monitoring. The the Manitoba Fire Commissioner’s Office, province does not require companies to from 1996 to 2004, farm building fires in report the findings of their air-quality Manitoba were responsible for an average of monitoring, but records must be kept and be $8.6-million a year in damages. available upon request of a safety and health officer. While the Manitoba government has Comment legislation requiring the establishment of Workers serve as sentinels for many workplace safety and health committees, health issues that could move into the Manitoba hog-production operations have general community. Furthermore, they are too few employees to meet the threshold at exposed to potential hazards at far greater which these committees are mandatory. concentrations than other members of Agricultural workers are not currently society. For these reasons, the Commission covered by The Workers Compensation Act, believes that monitoring and protection although some producers may choose to take of worker health will help to ensure the out voluntary coverage. In 2005, a public environmental sustainability of the hog- review of The Workers Compensation Act production industry. The limited number commissioned by the Manitoba government of people involved in inspecting hog- recommended that “WCB coverage of production facilities and the limited number workplaces should be extended gradually of inspections that are made suggest that over a three- to five-year period beginning there is a need for further resources in this with the inclusion of higher-risk workplaces area. Similarly, the Commission wishes to that are not already covered” (Legislative stress that hog-production workers need to Review Committee on The Workers be informed of the potential health risks Compensation Act 2005, 17). The Manitoba that they face and the importance of having government subsequently indicated that the appropriate protective equipment. it would be extending coverage following Finally, the Commission encourages the Fire stakeholder consultations. The Commission Commissioner’s Office to work with Manitoba encourages the government to meet the Agriculture, Food, and Rural Initiatives timetable set out by its Review Committee. (MAFRI) to develop a proposal that could Such a move would be an important first lead to the partial adoption of the National step in collecting local data on illnesses Farm Building Code for all new buildings related to the hog-production industry in over a specified size. The code would provide Manitoba. minimum requirements for human health, The most important decisions regarding fire safety and structural sufficiency. in-barn safety and health are those that are made before the barn is constructed. It is at Recommendations that point that the key decisions regarding ventilation and engineering are made. 11.3 The Manitoba government increase the Once the barn is constructed, ventilation resources of the Workplace Safety and problems become much more difficult to Health Prevention Service Branch to

132 Environmental Sustainability and Hog Production in Manitoba

provide for more inspection of hog- Such a disease outbreak would likely production operations. lead to a closing of the U.S. border to Canadian hogs. This would create a financial 11.4 The Manitoba government take steps to problem for hog producers who would have a modified version of the National no longer have market access. It would Farm Building Code apply in Manitoba further create an on-farm crisis, as the following consultation with concerned numbers of hogs would rapidly surpass parties. the holding capacity of hog barns. Within 96 hours of the closing of the U.S. border 11.2.2 Animal diseases (either because of disease in Canada or a Manitoba hog producers have instituted U.S. state), the population of isoweans in a number of different procedures to protect Manitoba would reach a crisis point. The animal health. These include, but are not response in other jurisdictions has been to limited to, the three-site production system, kill these healthy animals in what is termed biosecurity measures at each site, and the welfare slaughter. Research provided to the use of various feed additives to improve Commission stated that responsibility for health and prevent disease. These measures the carrying out of such a slaughter has not are intended not only to protect individual been included in any current North American animals, but to prevent the spread of disease emergency plans. The cost of welfare infectious animal diseases. slaughter can dramatically outstrip the In the last decade, outbreaks of highly cost of stamping out the disease. Intensive contagious animal diseases in Taiwan, the animal-production industries that are geared United Kingdom, and the Netherlands have towards export markets have among the led to a restructuring of industries and highest welfare slaughter costs. For example, widespread public debate over the future of the cost of the welfare slaughter in response the industries (The Royal Society 2004). An to the 1997-1998 outbreak of classic swine outbreak of a foreign animal disease, such fever in the Netherlands was $852-million as foot-and-mouth disease or classic swine U.S., while the cost of stamping out infected fever, would represent a significant threat to herds was $104-million U.S. It is estimated the Manitoba hog-production industry. Such the direct cost of stamping out a small foot- an outbreak could cause border closings, and-mouth outbreak in Canada (one that a particularly disastrous event given the affected 10,000 animals) would amount provincial hog industry’s dependence on to only one per cent of the total financial export markets for live hogs. impact of the outbreak once the costs of In Canada, the first step in any response the welfare slaughter and related losses are to a disease outbreak would be to attempt accounted for. to stamp out the disease by killing the In other jurisdictions, controversies infected animals: this would be accompanied have arisen in relation to the lack of by measures intended to trace, vaccinate, veterinarians, the lack of skilled personnel and quarantine or slaughter animals that to slaughter animals (ideally infected had been in contact with infected animals. animals should be slaughtered within 24 In Canada, the federal Canadian Food hours of identification and animals in Inspection Agency (CFIA) has responsibility herds that have made contact with infected for overseeing these measures, including animals within 48 hours), method of the authority to order the destruction of slaughter, and carcass disposal. infected animals and paying compensation While the CFIA has responsibility for for infected animals or animals that had the suppression of the disease on infected come into contact with infected animals. farms, Canada lacks both the framework and the funding to deal with the animal

133 Manitoba Clean Environment Commission welfare issues arising from an infectious plans should be a part of the permitting foreign animal disease outbreak. Without process. effective welfare measures in place, it may The issues brought about by an animal not be possible to eliminate the disease: a disease outbreak coupled with a border result that could lead to the collapse of the closing could have serious consequences for industry. (The level of existing commercial the social and economic sustainability of the slaughter capacity can make it possible for hog-production industry. The Commission a region to be declared disease-free in a believes the Manitoba government must play relatively short period. As a result, Quebec, a leadership role in developing a contingency which slaughters most of the hogs raised plan to address the potential consequences in the province, would experience a shorter of such an outbreak. At the same time, the period of border closing than Manitoba.) provincial government must work with the There would be no mandatory federal federal government and other provincial government response to the severe animal governments to develop a national agri-food welfare problem created by a border closure disaster response. The Commission also notes due to disease in the U.S. In this situation, that while the greatest problems would the provincial government may find itself arise from a disease outbreak, many of the having to take responsibility for organizing problems associated with such an outbreak the response. The welfare slaughter and could also flow from a politically motivated associated costs that accompanied swine border closing. fever and foot-and-mouth disease outbreaks in other jurisdictions have led to reduced Recommendations public support for those industries. In the Netherlands, the government adopted a 11.5 The Manitoba government take the lead policy intended to reduce the size of the in developing a contingency plan to industry and strictly license its operation. address the animal welfare consequences In 2006, the Manitoba government of a border closing. The planning should amended The Animal Diseases Act to allow account for both border closings caused the Chief Veterinary Officer to authorize by a large-scale animal disease outbreak welfare slaughter of livestock in emergency and those that arise for reasons such as situations (Whiting 2003; Whiting 2006; erection of trade barriers. Whiting n.d.). The Manitoba Pork Council has established an emergency planning 11.6 The Manitoba government work with committee in preparation for a potential producers to develop individual foreign animal disease outbreak or food contingency plans to respond to a safety issue. catastrophic event resulting in mass The Commission also notes a number mortalities. of Technical Review Committee (TRC) Reports recommended that proponents 11.2.3 Antibiotic use in hog production should consider preparing a contingency Antibiotics are administered to feed plan in case of a catastrophic event animals for three purposes: 1) to treat resulting in mass mortalities. While disease, 2) to serve as a prophylactic the TRCs have recommended that such at times of high risk, for example after plans be established, there is currently weaning or during transport, and 3) to no requirement for such plans. It is the promote growth or performance. It is not Commission’s opinion that such contingency uncommon for drugs to be classified for several categories at once. As noted in Chapter 6, there is a concern that the use of antibiotic drugs leads to the

134 Environmental Sustainability and Hog Production in Manitoba development of bacteria that are resistant and those that need a prescription. In to those antibiotics. This concern has led Canada, feed grain companies play a central to measures to reduce the prescription of role in the sale of antibiotics, since they antibiotics in the treatment of humans. It can add drugs to feed as long as they are has also led to calls for limitations on the on the federal government’s Compendium use of antibiotics for disease prevention of Medicating Ingredient Brochures (CMIB). and growth promotant in animal husbandry There is no requirement for a veterinarian’s (Khachatourians 1998; Levy 1998; McGeer prescription for the sale of these drugs. 1998; Shea 2004). It should be noted The Canadian Food Inspection Agency that there is no evidence to suggest that (CFIA) monitors the use of feed-additive antibiotic use in the treatment of animals medications primarily through facility is the primary cause of the development inspection, label inspection and feed of human antibiotic resistant bacteria. In sampling and testing programs at feed mills recent years, a number of studies have and farms in Canada. indicated that hog-industry workers have an A 2000 CFIA regulatory impact analysis elevated risk of development of the so-called statement reported “Feed-additive drugs superbug, methicillin-resistant Staphyloccus are commonly administered to livestock in aureus (MRSA) (Voss et al. 2005 and Khanna Canada to prevent or treat disease conditions et al. 2007). This has led Dutch medical or accelerate animal growth as part of authorities to screen hog-production workers conventional livestock production programs. who are admitted to hospital, for any Administering medications via feeds is reason, to determine if they are carrying considered a practical and cost-effective way MSRA (Moyer 2006). to treat groups of animals being raised for There is a potential pathway to connect breeding or food production purposes under the antibiotics used in agriculture and a variety of management systems.” The human beings. A study prepared for the report estimated that about 30 percent of Commission concluded that manure and feed used in Canada, whether manufactured wastewater spread on Manitoba fields are for commercial sale or made by producers likely to contain microorganisms that for feeding to their own livestock, contained are resistant to antibiotics or antibiotics medications (Government of Canada 2000). that can move into the environment. The In its submission to this Investigation, antibiotics and bacteria can reach people via the Manitoba Pork Council pointed to food or wastewater. While Health Canada the Canadian Quality Assurance (CQA) has mandated that, in general, the same program that the industry has developed antibiotics should not be prescribed to both and maintained as an on-farm food safety humans and animals, some overlapping use program for Canadian hog producers. It exists (Holley et al. 2007). is based on the principles of the Hazard The governance of the use of antibiotics Prevention Critical Control Point model. in agriculture is split: Health Canada Producers who wish to participate in the CQA evaluates the drugs and regulates their have to be validated to determine if they are sale and labelling, while the provinces meeting the program requirements. Under regulate the practice of veterinary medicine. the CQA program, producers are required to In Ontario, dealers must be licensed and, record the drug name, the manufacturer, in Quebec, the sale of veterinary drugs is whether or not it is being used under restricted to pharmacists and veterinary prescription, why it is being used, the surgeons. In Manitoba, there is no licensing dosage, the route of administration, requirement for selling these drugs. contraindication, cautions, and warnings, Federal regulation divides animal drugs where it is stored, and the withdrawal time. into those that can be sold over-the-counter

135 Manitoba Clean Environment Commission The form is to be signed by a veterinarian in particular. This is a situation that should and the producer. be rectified. For the Commission, the key concern with this issue is the lack of data. While it Recommendations does not appear that the antibiotic issue is currently a threat to the environmental 11.7 The Manitoba government enact sustainability of the industry, the regulations under The Animal Diseases provincial government lacks the data it Act to regulate the sale, use and requires to manage or ensure its long-term disposal of drugs for animals. This sustainability in this area. Simply put: there regulation should include the recording is no record of which drugs are being used of information on the drug types, or of the quantities of drugs being used. volumes, length of treatment, classes of Currently, it is not possible to compare the animals being treated, and purposes to amounts and classes of antibiotics used in which these medications are being used. the swine industry versus those prescribed This information should be compiled, to humans (Holley et al. 2007). analyzed, and reported to the public on The Animal Diseases Act gives the a regular basis. Manitoba government the right to regulate the sale of drugs for animals. 11.8 The Manitoba government work The government has not enacted any such with the federal government, other regulation. Elements of such a regulation provincial governments, and research might include: institutes to establish a comprehensive data collection network on antibiotic • Licensing of all vendors. resistance in food animals. • Requiring all vendors to have a place of business and proper storage facilities. 11.9 The Manitoba government monitor surface water for microbial • Prohibition on sales promotions. contaminants, especially in regions with high concentrations of intensive • Prohibition on selling expired drugs. livestock operations. • Recording of the name and address of the purchaser, along with the brand 11.10 The Manitoba government have hog name and quantity of the livestock manure examined for the presence of medicines sold. antibiotics and antibiotic resistant bacteria. • Prohibiting the repackaging of drugs. 11.11 The Manitoba government facilitate, • Requiring that each product must be encourage, and undertake further studies sold in the original package as it was into the efficacy and requirement for the received from the manufacturer. use of antibiotic drugs in feed animals. • A system for the return and disposal of expired and/or unwanted drugs. Similarly, in Manitoba, there is little monitoring of pathogen-related illness in food animals, the level of antibiotic resistance in food animals, or of the presence of such resistant microbes in the environment, in general, and surface water,

136 12 The approval process and watershed planning

12.1 Watershed planning production has not been able to remain in he preceding three chapters have balance with the landscape. dealt with the potential impacts The Commission is of the opinion that Tthat livestock operations can have the development of the hog-production on the environment and presented the industry can take place most effectively (and Commission’s recommendations as to how environmentally unsustainable clustering these issues can be addressed in a way that can be avoided) if decisions are made on will allow the industry to develop in an a watershed basis. This is in keeping with environmentally sustainable manner. The The Water Protection Act, which states that Commission recognizes that the move to a the Manitoba government “is committed to more sustainable form of production could watershed planning as an effective means to constitute a considerable financial challenge address risks to water resources and aquatic to some operators. This is, in large measure, ecosystems and believes that residents a result of the way the industry developed of watersheds should be consulted when in the past, particularly in the way it has watershed plans are developed.” The Act also clustered in specific geographic regions where identifies the importance of comprehensive

137 Manitoba Clean Environment Commission planning for watersheds, with respect to 12.2 The current approval process water, land and ecosystems, on a basis While the Commission believes that the that acknowledges and considers their long-term approach to addressing siting interdependence. decisions related to livestock development Under the Act, the government should be made on a watershed basis, it may designate watersheds and their believes that there is a need to address the boundaries and designate a water-planning current approvals process in the short term. authority for a watershed (which may be Like the Commission, the Livestock a conservation district board, a planning Stewardship Panel of 2000 wrestled with the district board, a municipal council, any issue of the approval process for livestock other entity or a combination of some operations. In its report, Finding Common or all of the above). The government can Ground, it concluded that a “two-approval” also set a date for establishing a plan and process was appropriate for Manitoba. Under provide the terms of reference for a plan. this approach, municipalities would make Among other considerations, watershed land-use decisions, while the provincial plans under the Act must take into government would make environmental account ”the capacity of the environment decisions. The Livestock Stewardship Panel to accommodate development, and any concluded that the existing system, by other matter related to present or future which the municipality took responsibility physical, social or economic factors.” The for land-use decisions, while the province Commission recognizes that the development issued manure storage and water rights of watershed-based planning and decision- licenses needed to be replaced by a new making is a complex process. For example, process. It recommended that: no municipal boundaries coincide with New and expanding ILOs should watershed boundaries. While Conservation require formal approval by both the host District boundaries are more closely aligned municipality for compliance with its with watershed boundaries, they currently land use by-laws, and the province for lack the authority and the legitimacy to environmental impact before construction take on many of the land-use planning is allowed to begin. (Livestock Stewardship responsibilities held by municipalities. Panel 2000, 25) Despite this, many municipalities and While the provincial government local planning authorities are already made Technical Review Committee reports taking watershed issues into consideration mandatory for operations over 300 animal when they make their planning decisions, units, and gave the Technical Review particularly when there is a local Committees additional authority, it did Conservation District in place. The Swan not introduce the environmental approval Valley Planning District, for example, system that Finding Common Ground had generally fits with a watershed boundary envisioned. The Commission endorses the and the Commission encourages new and Livestock Stewardship Panel’s two-approval existing districts to consolidate, where approach. In assessing the current approval possible, along watershed boundaries. process, the Commission was also guided The paper prepared for the Commission by those guidelines in The Sustainable by the International Institute for Development Act that call for public Sustainable Development entitled Toward participation, access to information, and Watershed-Based Decision-Making and integrated decision-making. Total Nutrient Loading Reduction (Oborne The current approvals process, for et al. 2007) outlines one path that the operations of 300 or more animal units, Manitoba government could consider for the involves three key elements: implementation of its water strategy.

138 Environmental Sustainability and Hog Production in Manitoba

• The report prepared by the provincial specified surrounding area, in terms of the Technical Review Committee. assimilative capacity of the land base of the proposed facility, and neighbouring • The rural municipality’s decision as to livestock operations (within a two-kilometer whether or not to grant a conditional– radius), to utilize livestock manure on a use permit. sustainable basis as a crop nutrient.” As part of the cumulative assessment, the TRC • Manitoba Conservation’s decision as to would also review soil test information to whether or not the proposed manure- determine a baseline of soil fertility levels storage facility meets with permitting of the proposed spread fields (Manitoba criteria. Government 2000b). The Commission has the following TRC members are not always able comments on these three elements. to conduct on-site visits prior to the completion of the report (this can be for a 12.2.1 Technical Review Committees variety of reasons, including the season and The regional Technical Review staff familiarity with the site). For these and Committees, which are chaired and other reasons, there have been situations coordinated by Manitoba Agriculture in which the TRC report has contained Food and Rural Initiatives (MAFRI) have erroneous information. The TRC reports, seen their roles and responsibilities grow in effect, acknowledge their limitations by considerably since they were first established assuring readers that: in the mid 1990s. A major contribution of the TRC is that it provides a public There will be another review and report at an early stage in the approval approval at the provincial level on process. Unfortunately, these reports are, the environmental aspects of the at times, based largely on a fairly limited proposal, which will require more on- information base. According to a terms-of- site engineering and soil information reference document for the TRC process that regarding the storage and application of was provided to the Commission, the TRC the manure produced by the operation. requires the following information: The Planning Act states that a • A completed livestock production municipality cannot approve a project information sheet. unless a TRC has concluded that “based • Application for Local Planning on the available information, that the Approvals, where required. proposed operation will not create a risk to health, safety or the environment, or • Soil test results indicating nitrogen and that any risk can be minimized through phosphate levels in the fields on which the use of appropriate practices, measures it proposed to apply manure. and safeguards.” None of the TRC reports The TRCs also make use of published reviewed by the Commission made specific information on such issues as soils, geology, use of this language. In one case, where hydrogeology, water well logs, land-use sufficient acres for manure application were and zoning policies and bylaws, The Farm not available, the opinion that the project Practices Guidelines, the Livestock Manure should not be approved was attributed to and Mortalities Management Regulation the Department of Conservation, as opposed (LMMMR), and other provincial regulations. to the TRC as a whole. It was left to the In assessing cumulative impacts, the municipal council to determine if the TRC TRC is to describe “the potential effect had or had not concluded that the project of a proposed livestock operation on a would “not create a risk to health, safety or the environment.”

139 Manitoba Clean Environment Commission As a result of the fragmented nature For this reason, it favours a continuation of the TRC reports, the current process of the policy of requiring conditional- does not appear capable of providing use approvals for all ILOs. It also believes clear direction in controversial cases. The that this planning must take place in the Commission wishes to make it clear that context of a publicly developed and accepted it does not attribute the shortcomings it livestock operation policy. The Commission has identified to any of the individuals does not recommend the introduction of involved with the TRC process. What an appeal process for municipal council started as an advisory committee has decisions. slowly been asked to take on a range of different and, at times, conflicting roles. 12.2.3 The provincial permitting The confusion was apparent even in the process 2006 Manitoba Conservation publication As noted earlier, the TRC report states on the environmental sustainability of the that the proposal for a new or expanding hog-production industry. In the text, it was livestock operation will undergo “another stated that the TRC is not a decision-making review and approval at the provincial body, while in the accompanying diagram, level on the environmental aspects of the readers were informed that proposals must proposal.” This refers to the permitting be rejected by council if TRC recommends process for a manure-storage facility required ‘No’” (Manitoba Government 2006, 18-19), by the LMMMR. As outlined in Chapters which suggests that TRC recommendations 7 and 9, there is a significant assessment have, in effect, the power to stop proposals. process at this point. That assessment, however, is limited solely to the integrity of 12.2.2 The conditional-use process the proposed manure-storage facility and the The municipal process called for in The proponents’ access to sufficient land to apply Planning Act, with its mandatory livestock manure at up to twice the phosphorus crop operation policies (LOP, described in Chapter removal rate. Issues such as biodiversity, 7), mandatory public notices, posting of emissions to the atmosphere, and impact on properties, advance publication of the the larger watershed are not assessed in this TRC report (recognizing the limitations process. Nor does this process result in the of these reports), public debate, and a issuance of a public report. public decision, reflects the spirit of The Sustainable Development Act Guidelines for 12.3 A new approval process public participation, access to information, The Commission is proposing the same and decision-making and planning. Recent dual approval process as recommended changes to The Planning Act have introduced by the Livestock Stewardship Panel. The a great deal more predictability into the rural municipality would be responsible process. In particular, municipal authorities for land-use decisions, while Manitoba are required to have LOPs in place as Conservation would be responsible for part of their development plans by 2008. issuing permits for manure-storage facilities These LOPS are to be developed through a to all new, modified, and expanding process of public consultation, taking into livestock operations. The Commission consideration such matters as soils, the size recognizes that livestock operations and of the livestock operation, proximity to their manure storage facilities are relatively significant surface water bodies, flood risk, straightforward and predictable in nature. groundwater vulnerability, and proximity to While it is not recommending that such residential and recreational development. projects be subject to a full environmental The Commission believes that local control licensing process, it is proposing stricter is an important aspect of land-use planning. requirements and broadening the range

140 Environmental Sustainability and Hog Production in Manitoba of items requiring assessment. Chapter • A description of the proposed 11 of this report, for example, contains development. recommendations calling for the inclusion of biodiversity conservation considerations • Manure-storage facility siting into the provincial decision-making process information (distances from regarding the expansion in the livestock watercourses, water sources, surface sector or significant changes in land use. water recharge areas, property boundaries, residences, and designated It is essential that the public be areas (urban centres or settlement provided with the information on which the centres; rural residential or seasonal land-use and environmental decisions are to residential areas; and parks or be made, that the public be allowed to have recreational areas, significant wildlife a meaningful input into those decisions, habitats)). This would also include and that the decision making process be depth to groundwater table, flood return clear and transparent. For these reasons, period, and the presence of abandoned the Commission is proposing that the wells. current TRC process, be replaced with a site- • Detailed information on the form of assessment and review process that would manure-storage facility being proposed. be coordinated by Manitoba Conservation. Advice should be sought from other • Detailed manure application departments as appropriate, but their role information including whether there is should be strictly advisory. The proposed a requirement to convert native habitat process is described below and outlined in to cropland to accommodate manure Figure 12.1. application.

12.3.1 Site assessment • A demonstration that the operator has The Commission is recommending access to sufficient cropped land base that the Manitoba government require to balance phosphorus application rates that proponents of the construction, with removal rates over the long-term. modification, or expansion of a manure- storage facility be required to submit a site • Detailed site and design plans. assessment at the start of the application • Soil characteristics of the site the process. This site assessment would be facility is to be built on. prepared by the proponent and would address issues identified by both the • Soil characteristics of the spread fields. municipality and the provincial government. It would be more extensive than the • An identification of which subwatershed information contained in the TRC reports. and watershed the operation will be It would include, but not be limited to the located in. following issues: • Land ownership. 12.3.2 Reviewing the site assessment The review process should be lead by • A description of the existing land use Manitoba Conservation, the permitting and adjoining land use. authority, with the assistance of a central provincial government technical advisory • Proposed changes to land use, committee (TAC) that would screen the immediate and future. site assessment to determine if further information is required from the proponent. • Land-use designation for the site. The TAC would consist of representatives

141 Manitoba Clean Environment Commission STOP Permit Denied Permit If conditions not met Construction & Inspection While operational compliance with: While operational Contaminated Sites Act Regulation, Contaminated Incinerator , LMMMR, Dangerous Goods, Litter Regulation, Goods, , LMMMR, Dangerous Act Environment Application may be Approved With or Without Conditions if Application may be Approved s$EVELOPMENTPLANPOLICIESANDZONINGMET s,OCATIONANDSETBACKSMET s)FDEEMEDCOMPATIBLEWITHSURROUNDINGAREA AND s)FDEEMEDNOTDETRIMENTALTOHEALTHOFPEOPLEINAREA Permit Conditions Met Permit Development Permit Issued Permit Development Application Public Notice Screening of Site Assessment of Screening STOP Municipal level public hearing Municipal level Permit Denied Permit within 3 kilometres and all neighbouring municipalities) all neighbouring and within 3 kilometres (Minister, newspaper notice, posting, mailing to all landowners mailing posting, notice, newspaper (Minister, to municipal authorities, provincial departments, and the public. the and departments, provincial authorities, to municipal Rights Licence, if required). Applicant submits a full site assessment. Applicant if required). Licence, Rights Screening process conducted by a by Technical Advisory Committee led by Advisory by a Technical conducted process Screening for a Conditional Use Permit and Manure Storage Permit (and Provincial Water Water Provincial (and Permit Storage Manure and Permit Use a Conditional for assessment made available to public. TAC report and public comments released released comments public and report TAC available to public. made assessment Manitoba Conservation. Screening of Site Assessment to include site visit. Site to include Site Assessment of Screening Conservation. Manitoba Provincial Manure Storage Permit Storage Manure Provincial Permit Issued Permit Licence Issued Application Denied by Council if Application Denied by s$EVELOPMENTPLANPOLICIESORZONINGNOTMET s,OCALOR0,50LOCATIONANDSETBACKSNOTMET s)FNOTDEEMEDCOMPATIBLEWITHSURROUNDINGAREA OR s)FDEEMEDDETRIMENTALTOHEALTHOFPEOPLEINAREA STOP STOP Provincial Water Rights Licence Water Provincial Licence Denied Figure 12.1 Proposed approval process approval 12.1 Proposed Figure 142 Environmental Sustainability and Hog Production in Manitoba from a core of provincial government Should environmental issues that were not departments and be augmented with others addressed be raised at the conditional- as each situation called for. Suggested core use hearing, they should be referred back membership would include members from to Conservation. Should the municipality Conservation (Livestock Program and Wildlife approve the proposal, the proponent would and Terrestrial Ecosystem Management), then apply to Conservation for a permit Water Stewardship (Surface Water, Water under the LMMMR and to Water Stewardship Quality, Groundwater, Licensing, and for a water rights licence (if required). Fisheries), Intergovernmental Affairs, Manitoba Conservation should be able to Agriculture Food and Rural Initiatives assess whether the proponent meets the (Agri-Environment), and Infrastructure and requirements for the issuance of a permit Transportation. Other departments that based on the information that had been might be consulted could include Health supplied in the initial site assessment. and Labour, depending on the issues under In short, the Commission believes that consideration. A Manitoba Conservation the process it is proposing would allow for representative would chair and coordinate an early and public identification of all the work of the TAC. Consultations should relevant issues and provide the public with be undertaken with local soil and water an opportunity to make informed written associations, such as a Conservation District. submissions to Manitoba Conservation and make an informed contribution to the 12.3.3 Public input into the site municipal conditional-use process. Decision- assessment makers would have more information on The site assessment would be placed on a wider range of issues available to them the appropriate public registry and made at an early stage in the process. While available to the appropriate municipal proponents would be required to produce offices. The public would be invited to more information in the early stages of submit comments to Conservation on the the process, the more comprehensive proposal. At the end of the screening examination and review of the proposal by process, which would include a mandatory the TAC should provide greater predictability site inspection by a Manitoba Conservation to the process. representative, Conservation would issue a public report on the project, similar to Recommendation those currently produced for environmental licenses, identifying the relevant land- 12.1 The Manitoba government adopt a new use and environmental impact issues. This approval process for new, modified, and report, the site assessment, and the TAC expanding manure storage-facilities comments, would go to the municipality, operations as detailed in Chapter 12. the local offices of relevant provincial Under this process, proponents would departments, and the public registry. Public submit detailed site assessments that comments submitted during this process would be screened by a provincial would be part of the report. Technical Advisory Committee coordinated by Manitoba Conservation. 12.3.4 The process following the The review process would produce a completion of a site assessment report that would be available to the When the site assessment has been public, along with the site assessment. screened by the TAC and accepted by This report, the site assessment, and Manitoba Conservation, the proposal would the TAC comments, would go to the proceed to the municipal authority for its municipality and the local offices review and approval of a conditional permit. of relevant provincial departments.

143 Manitoba Clean Environment Commission Responsibility for determining land- use issues would remain with the municipal authority, while the provincial government would retain responsibility for the issuance of environmental approvals.

144 13 Information and research

hroughout this Report, the Commission for the government to withhold certain data has identified information gaps and called that it collects, particularly when it affects Tfor additional research. The Commission the privacy or proprietary concerns of other recognizes that government also has a role to Manitobans, the Commission favours an play in ensuring that information is available approach that makes information of public to decision makers and the public in a timely interest available on a regular basis. This and ongoing manner. The Third Guideline for chapter surveys the key information and Sustainable Development in The Sustainable research issues and makes two overarching Development Act highlights the value of recommendations. “Access to Information—which means (a) encouraging and facilitating the improvement 13.1 Information and refinement of economic, environmental, In its 2000 report, the Livestock human health and social information; and Stewardship panel commented that it (b) promoting the opportunity for equal was “surprised at the lack of assembled and timely access to information by all information on the distribution of the Manitobans.” While there can be good reasons livestock industry around the province.”

145 Manitoba Clean Environment Commission It called for the establishment of an • Water supply and water use data for the information system that would “provide livestock sector. Manitobans with a means for more accurately tracking the environmental • The use of antibiotics and the presence effects of present and future livestock of antibiotics in the environment. operations (as well as other industrial • Pathogens in manure, soil, groundwater operations that might impact on water and surface water. quality)” (Livestock Stewardship Panel 2000, 49). Seven years later, the Commission finds • Illnesses related to hog operations. that both comments retain considerable validity. There is a great deal of information • Heavy metals in agricultural soils in about the hog-production industry that is relation to the application of manure not known. Second, there is a great deal of fertilizer. information that is known that is not readily There also needs to be improvements available to the public. in reporting on the number, type, and There are varying reports of the location of livestock operations. The number of hog production operations Auditor General reported a reluctance on the landscape. Some of this variation on the part of Manitoba Agriculture, is understandable: the Manitoba Pork Food and Rural Initiative staff to share Council reports on producers who meet information regarding the location of non- specific marketing requirements, while permitted manure-storage facilities with the basis of Manitoba Conservation’s Manitoba Conservation staff. Environmental understanding of the size of the industry sustainability requires that MAFRI springs from operators that have been and Manitoba Conservation, and other required to either file manure management departments work cooperatively to collect, plans or seek permits for manure- report, and share data. storage facilities. While there have, in There is also a need for the public the past, been recommendations to have release of information on a regular basis. all livestock operations with over 300 Manitoba Conservation and Manitoba Water animal units register with the province, Stewardship are collecting data on a wide this recommendation has never been range of issues. Reports should be provided implemented. Perhaps the most problematic on such matters as: result of this approach is the fact the • Nutrient concentrations and loading of provincial government does not have a tributaries, particularly those in areas of clear handle on the number of operations intensive livestock operations. that have manure-storage facilities that were constructed prior to 1994, the year in • Nutrient analysis assessed annually to which the province began permitting such identify trends and measure potential facilities. impact to surface water. A brief list of areas where, in the previous chapters, the Commission has • Soil test data and trends based on recommended improvements in data manure-management soil tests. collection and compilation includes: • Water quality trends based on the • Water quality information, which is monitoring-well and source-water incomplete for large rivers and non- analysis. existent for small streams. • Ambient and indoor (barn) air-quality • Identification of ecologically sensitive data in the vicinity of intensive sites. livestock operations.

146 Environmental Sustainability and Hog Production in Manitoba

• Enforcement and inspection. manure handling, cropping systems, soil, air and water health, animal welfare, and food Recommendations safety. MPC contributed $750,000 to the Centre. 13.1 Manitoba Conservation and Manitoba The University of Manitoba, Manitoba Agriculture, Food and Rural Initiatives Agriculture, Food, and Rural Initiatives develop a common database to record (MAFRI), and MPC also collaborated in the the presence of all Manitoba livestock establishment of the Swine Research and operations. Development Centre Consortium in Brandon, which provides a series of research and 13.2 The Manitoba government develop and evaluation services to the hog production publish a series of trend reports on the industry. data that it collects and compiles on Another source of support for research water quality, soil quality, air quality, is the Agri-Food Research and Development and health issues related to the raising Initiative (ARDI), which is funded by of livestock. MAFRI and Agriculture and Agri-Food Canada. It supports research intended to assist producers and consumers and the 13.2 Research development of technologies, production The Commission is recommending that methods, and markets. Administered by the Manitoba government conduct, facilitate, the Manitoba Association of Agricultural collaborate on and commission research Societies, it has supported a variety of in a number of areas. The Commission is research related to hog-production and the not identifying which projects should be environment. undertaken by government alone and which The Deerwood Soil and Water research partners should be engaged for Management Association, established in other projects. 1984, is made up of approximately 120 Since the expansion of the industry in farmers within an 875 square kilometre the late 1990s, Manitoba researchers have area (342 square miles) along the Manitoba been engaged in a wide variety of projects Escarpment in South-central Manitoba. The related to the hog-production industry. Association has conducted research into The industry itself, through the Manitoba such practices as zero and minimum tillage, Pork Council (MPC), has played a critical rotational grazing, shelterbelts, and small role in funding this work. The MPC and the dam construction. In 2004 it was contracted Manitoba government were instrumental in to undertake an extensive investigation establishing the Manitoba Livestock Manure into the effectiveness of a series of best Management Initiative (MLMMI). The MLMMI management practices. It is one of seven coordinates research on manure management such projects across the country one of only and has invested in excess of $3.5-million in two in the Prairies. It has also been involved nearly 50 projects, with nearly half of that in studies into the impact of replacing amount coming from the MPC. synthetic fertilizers with manure. The University of Manitoba has The Commission supports the extensive established a National Centre for Livestock role that the industry has played in and the Environment at its Glenlea Research supporting research and the way the Station. The 486-hectare research and academic community has become involved in teaching facility’s long-term goal will be research that is directed towards addressing to develop environmentally sustainable pressing local issues. The Commission urges livestock production practices. Issues that the government to take the necessary steps it will be addressing are animal housing, to ensure the integrity of the research. As

147 Manitoba Clean Environment Commission issues become increasingly complex and partnership between universities, colleges controversial, it will be necessary to require and government agencies. more peer review of research. It will also be necessary to broaden the range of issues Recommendation that are under examination. In the process, a broader range of disciplines are likely to be 13.3 A Watershed Studies Institute be called upon to engage in research related to established to coordinate information the sustainability of this sector. collection, analysis, and evaluation, direct research and provide support to It is preferable to move towards a agencies and organizations undertaking watershed-planning model for making watershed management in Manitoba. decisions on the location of developments such as hog-production facilities. Moving 13.3 Communication and to such a model will require changes in information coordination political structure, which may take a As noted earlier, the hog-production considerable period of time. Furthermore, sector is governed by a number of legislative we do not currently have the full range of acts, which are administered by a several information (both in terms of scientific different provincial departments and understanding of the movement of nutrients agencies. Staff from Manitoba Conservation, through watersheds and the background Manitoba Water Stewardship, Manitoba levels of nutrients in the environment) to Intergovernmental Affairs, and Manitoba allow for truly effective watershed planning. Agriculture, Food, and Rural Initiatives, The province has a well developed set Manitoba Labour, and the Manitoba Farm of academic resources: the universities Practices Protection Board may at some have considerable research and analytical point become involved in making decisions capability when it comes to water quality that affect the future of an individual hog and water engineering related issues, and producer. These decisions can be based the colleges have a great deal of applied on The Environment Act, The Water Rights engineering knowledge in hydrology and Act, The Farm Practices Protection Act, water quality. In both cases, students are The Planning Act, The Workplace Safety often engaged in research that relates to and Health Act, and the Livestock Manure Manitoba water. The opportunity exists to Management and Mortalities Regulation, bring these resources together in a multi- to cite only a few of the applicable pieces disciplinary inter-institutional Watershed of legislation. Furthermore, municipal Studies Institute. Aside from carrying out authorities play a key role in the permitting research into watershed issues common to process, particularly when it comes to all Manitobans, the Institute could serve putting in place odour-control measures. as a resource to the provincial government, It was apparent from the public meetings municipalities, and conservation districts as and research prepared for the Commission, they address watershed-planning issues. that many members of the public, including Advantages of such an institute producers, find this array of agencies would stem from focusing and partnering confusing. The merger of the departments the research expertise resident in the of Natural Resources and Environment to province on watershed issues of concern, create Manitoba Conservation, the creation while providing a means to house and of Manitoba Water Stewardship, and the share watershed knowledge and data. An introduction of the Nutrient Management institute would have greater leverage to Regulation have all further complicated seek funding while fostering a climate of matters. Legitimate confusion exists as to the responsibilities of various departments.

148 Environmental Sustainability and Hog Production in Manitoba

The Commission recognizes that, necessarily unhealthy. At the same time, the in a complex world, numerous pieces of Commission believes consideration should legislation will apply to an activity such be given to the establishment of a steering as hog production, which has social, committee on agri-environmental and economic, and environmental implications. societal issues. Issues of interdepartmental It also recognizes that it is appropriate for and intergovernmental cooperation were different departments to have different also raised by the Auditor General. The responsibilities in addressing environmental Commission agrees with the Auditor issues. General that there are “many advantages in The Commission believes the Manitoba cooperating and communicating with other government should implement measures departments and municipalities.” that would assist members of the public in general, and producers in particular, in navigating this increasingly complex system. This could include an interdepartmental communication strategy that would see the development of plain language documents explaining the pertinent pieces of legislation and the roles of the various government departments—and the branches and agencies affiliated with those departments. Such a communication strategy would also ensure that calls made to an inappropriate government office are re-directed to the appropriate office. The appropriate contact information (phone numbers and addresses) should be posted in the appropriate government offices, particularly in rural Manitoba and should be made available to the appropriate municipal authorities. A toll-free number to which members of the public could report concerns could be established and publicized. Consideration should also be given to measures that allow Manitoba Conservation Environmental Officers to be distinguishable in the field and at public events. Throughout this report, the Commission has identified the work that various provincial governments are undertaking in relation to agriculture and the environment. Various reports have indicated that, in other jurisdictions, it is not uncommon for there to be tensions between departments mandated with development and environmental protection. It has been suggested to the Commission that similar tensions exist in the Manitoba government. This is neither unexpected nor

149 Manitoba Clean Environment Commission

150 14 Conclusion

Scenarios for the future in Winnipeg and Saskatchewan. Furthermore, s outlined in Chapter 5, the Manitoba the proposed OlyWest project appears to be hog-production industry is facing a currently in a state of abeyance. number of significant challenges. Two Loss of access to the U.S. market for A live hogs could lead to either a reduction of these issues, the increasing value of the Canadian dollar and the U.S. government’s in production or an expansion of slaughter coming Country of Origin Label, severely capacity and an expansion of the number threaten the profitability of Manitoba’s of hogs being raised to slaughter weight in exports of live hogs to the United States. In Manitoba. 2006, Manitoba exported 5.4 million hogs A move to increase the number of (4.1 million weanlings and 1.3 million market hogs finished in Manitoba would have hogs) to the U.S. This issue is compounded environmental implications. For each by the lack of slaughter capacity in Manitoba. additional one million hogs finished in While Maple Leaf Foods is adding a second Manitoba (as opposed to being exported to the shift at its Brandon plant, this move has been U.S. as weanlings) there would be an increase coupled with the loss of slaughter capacity of 15 to 20 per cent in overall nitrogen and

151 Manitoba Clean Environment Commission phosphorus production. Approximately further action is needed to ensure the 4,200 tonnes of nitrogen and 800 to 1,100 industry’s environmental sustainability. tonnes of phosphorus would be produced The phase-in period for the phosphorus (the phosphorus production would vary on regulation, particularly for areas where the amount of phytase added to the feed). there is a serious imbalance in phosphorus An additional 80,000 to 110,000 hectares of application and removal stretches too spread fields would be required to maintain far in the future. For this reason, it has a balance between phosphorus application recommended that full compliance with the and removal under the current regulations. phosphorus regulation for all operators be This would raise the arable land on which required by 2013. hog manure was being applied to between There is a need for considerable increase approximately 580,000 to 810,000 hectares, in data gathering, compilation, and research representing 12-16 per cent of Manitoba’s in a number of key areas. In particular, agricultural land base (as opposed to 10- the Commission believes it is necessary 15 per cent for current production) (Flaten to prepare for a five-year review of the personal communication). phosphorus restrictions. The Commission Finishing the four million weanlings urges the government to ensure that the currently shipped to the U.S in Manitoba necessary research and monitoring is would produce a 60 to 80 per cent increase undertaken to facilitate a full review of the in nitrogen and phosphorus and require an regulation in five years time. additional 320,000 to 440,000 hectares of The approvals process needs to be land. broadened in terms of the number of issues Although the economic and agricultural that it assesses, including broader watershed future is difficult to predict, particularly issues. While the approval process involves given current trends in the value of the many issues other than the regulation of Canadian dollar and the price of feed, any manure phosphorus, the decisions made future growth in hog production may well at this point are crucial in preventing take the form of an expansion of finishing industry concentration from exceeding barns. As the numbers above suggest, the landscape’s capacity for phosphorus this could lead to a significant increase in application. As part of a new approvals nutrient production. While such an increase process, the Commission is recommending in the amount of available manure would that new operations be required to provide an economic benefit for farmers demonstrate that they have a sufficient looking to reduce their reliance on synthetic cropped land base available to balance fertilizers, there would also be need for phosphorus application rates with removal careful management of the environmental rates over the long-term. concerns. In addition to action in these three areas, the Commission has made The Commission recognizes that given recommendations related to the hog various economic factors, this development production industry’s impact on a range may well not materialize. If it does, there of environmental issues including winter is a risk that development will once more application of manure, water supply, water become too densely concentrated, creating quality, climate change, odour, land-use, new regional imbalances. This would be biodiversity, and human and animal health. especially true if the recommendations of While the Commission does not believe that this report were not implemented. these issues currently represent a serious barrier to industry sustainability, action now In the end, the Commission has will allow the province and the industry to identified three overriding areas where better manage these issues into the future.

152 Environmental Sustainability and Hog Production in Manitoba

The Commission also wishes to underscore a point that it made at the beginning of this report, namely that this has been an examination of the environmental sustainability of the hog- production industry. The Commission is well aware of the fact that some of its recommendations will have economic impacts for producers. Much of the focus in this report has been on regulation and enforcement. There is an equal, if not more important, role to be played by those who work for the government doing agriculture extension work, environmental farm planning, and in developing programs that reward farmers for providing environmental farm services. When the Manitoba government adopted the new phosphorus regulation, it indicated that it would be providing producers with financial assistance in adjusting to these regulations. Environmental sustainability is achievable, but it cannot be put off into the future. The challenge for the government will be to develop an implementation strategy that works with producers and other members of society to ensure the industry’s social and economic sustainability. In those areas where nutrient production is currently out of balance with the environment’s ability to remove those nutrients, the province and producers must move quickly and cooperatively to bring production into balance within the next five years. Given the scenario sketched out at the start of this chapter, the government must put in place a framework that will see that all future growth is balanced growth and that the industry’s development is environmentally sustainable.

153 Manitoba Clean Environment Commission

154 15 Recommendations

9.1 The phase-in dates for the Livestock regulation has been in place for five years. Manure and Mortalities Management The review should include: Regulation phosphorus provisions be adjusted so that all operators are required • Trends in soil test phosphorus by to be fully compliant with the regulation region. by 2013. • Enforcement effectiveness and compliance. 9.2 The ban on the winter application of manure in the Livestock Manure and • Effects of soil test phosphorus values Mortalities Management Regulation be on adjacent watercourses/water quality. extended to all operations by 2013. • Evaluation of thresholds. 9.3 The Manitoba government undertake a • Evaluation of risk assessment tools. review of the phosphorus application provisions of the Livestock Mortalities and Manure Management Regulation after the

155 Manitoba Clean Environment Commission • Evaluation of management practices to balance phosphorus application rates to reduce phosphorus-related with removal rates over the long-term. environmental risks. 9.8 The Manitoba government and industry Such a review will depend on the encourage producers to move to barn availability of a wide range of water and manure-storage facility management quality data. The water monitoring that maximizes spring and summer efforts needed to acquire these data supply and application. should commence immediately. 9.9 The Manitoba government facilitate, 9.4 The Manitoba government immediately encourage, and undertake further studies conduct, facilitate, collaborate on into the cumulative effects of applying and commission research on soil test manure fertilizer to marginal lands. phosphorus and transport mechanisms This should include the examinations of that will lead to the calculation of a pathogen movement and transfer, and phosphorus threshold specifically for nutrient run-off. Manitoba soils and climatic conditions. This research should include an 9.10 The Manitoba government assist examination of the effectiveness of a producers in efforts to adopt and phosphorus index for Manitoba. This develop techniques that reduce the threshold should be considered in the liquid volume of manure. Such measures review of the phosphorus regulation. would reduce the cost of transporting nutrients, resulting in more effective 9.5 The Manitoba government work use of manure nutrients and a reduction with other organizations to develop in the pressure to convert natural lands science-based, environmentally, to croplands. and economically sound beneficial management practices for reducing 9.11 The Manitoba Government reconcile the phosphorus losses to surface waters differences in terminology (particularly under Manitoba’s soil, landscape, and in relation to zones and classifications) climatic conditions. in the Livestock Mortalities and Manure Management Regulation and the 9.6 The Manitoba government provide Nutrient Management Regulation. livestock operators with financial assistance or incentives to assist them 9.12 The Manitoba government develop in coming into compliance with the a nutrient budget for agricultural phosphorus provisions of the Livestock Manitoba on a sub-watershed and, Manure and Mortalities Management ultimately, a watershed basis. Regulation. This should include funding for the implementation of effective 9.13 The Manitoba government facilitate, beneficial management practices. encourage, and undertake further studies to identify: 9.7 The Manitoba government amend the Livestock Manure and Mortalities • Practices and technologies that can Management Regulation to require further protect the environment, that new and expanding operations be animals and humans from pathogen required to demonstrate that they have distribution from hog production. a sufficient cropped land base available This should include determining the role played by the nitrogen and

156 Environmental Sustainability and Hog Production in Manitoba

phosphorus limits governing manure Facility Operators, certification should application in Manitoba and studies be valid for five years. of transfer mechanisms. 9.17 Concrete and steel manure-storage • Practices and technologies that will structures be inspected every three effectively reduce or eliminate the years by a qualified structural engineer. pathogen content in agricultural manure in Manitoba. This 9.18 The Manitoba government facilitate, should include research into the encourage, and undertake further effectiveness of multi-cell storage studies with respect to migration of facilities and whether treatment of liquid manure seeping through the earth manure with ammonia or urea can towards an aquifer and the resulting eliminate pathogens from livestock long-term effect on groundwater manure in Manitoba. supplies. • The pathogen related-risks facing hog-production workers and steps 9.19 The Livestock Manure and Mortalities that can be taken to eliminate and Regulation require compliance with the reduce those risks. provisions of the Technical Reference Manual for Liquid Manure Storage • The incidence of pathogen-related Structures. illness and the connection between such illnesses and the livestock 9.20 The Manitoba government report all sector. significant manure-storage facility design changes to the appropriate • How pathogens in manure fertilizer, municipal authorities. particularly surface-applied fertilizer, may affect wildlife. 9.21 The Manitoba government continue its policy of having Manitoba Conservation 9.14 The Manitoba government facilitate, Environment Officers inspect all licensed encourage, and undertake further studies manure-storage facilities on an annual in the assessment of heavy metals in basis with a priority being given to the Manitoba agricultural soils and potential high-risk operations. environmental effects as a result of long-term application of manure. 9.22 The Manitoba government require all new, modified, or expanding hog- 9.15 The Manitoba government require production operations to register manure that, where new above-ground steel or management plans. concrete storage facilities are located, dyking be constructed to provide a 9.23 The Manitoba government ensure that secondary containment area equal to Manitoba Conservation has sufficient 110 per cent of the capacity of the resources to assess proposed hog- structure. production operations, inspect existing operations on an annual basis, audit 9.16 The Manitoba government require 10 per cent of manure management certification of manure-storage plans annually, register non-permitted facilities operators, similar to the Water manure-storage facilities, and and Wastewater Facility Operators enforce existing manure-management certification. As with Water and Waste regulations.

157 Manitoba Clean Environment Commission 9.24 The Manitoba government obtain synthetic covers (ideally negative accurate data on livestock water pressure covers). sources, quality, and usage. This would include the reading of meters 10.2 The Manitoba government require all at livestock operations by Manitoba new and expanding operations to either Conservation Environment Officers at the inject or incorporate manure, with time of inspection of manure-storage incorporation taking place within 48 facilities, the comparison of meter hours. readings with allocated amounts, and the publication of annual summaries of 10.3 The Farm Practices Protection Board use versus allocation for each sector. cease requiring complainants to place a $50 deposit when they file a complaint. 9.25 The Manitoba government compile information on technologies that reduce 10.4 Manitoba Conservation Environment water usage without compromising Officers be given the authority to animal performance and make this enforce orders of the Farm Practices information available to producers. Protection Board under their powers under The Environment Act. 9.26 The Manitoba government facilitate, encourage, and undertake further studies 10.5 The budget of the Farm Practices into water use, water wastage, and Protection Board be increased to allow water use reduction technologies and it to undertake more outreach work to practices. This should include: make members of the public aware of its services. • The use of water by genotype, production phase, environment and 10.6 The Manitoba government establish a health status. dispersion-theory-based farm odour • The amount of water used by guideline. Such a guideline would give unmetered operations engaged in hog consideration to the various factors that production. affect odour emission and dispersion including topography and technology. • Animal management strategies and animal housing designs that minimize 10.7 The Manitoba government facilitate, water usage and wastage and encourage, and collaborate on the therefore reduce manure volume. research and data collection in the following areas: • Waste water recycling for existing operations that may not be able to • Standards and procedures for significantly reduce water use because measuring odour emission from barns of design. and manure storage in Manitoba.

• Hog rations that minimize excess • Potential health effects associated nutrients and mineral intake, thus with odour downwind from hog influencing water intake as well as operations. These are needed to manure output. establish suitable acceptability criteria for community level exposure 10.1 The Manitoba government require that to odour. all new manure-storage facilities have • Emission rates and characteristics of odour from hog operations.

158 Environmental Sustainability and Hog Production in Manitoba

• Downwind distribution of odour and 11.6 The Manitoba government work with other air contaminants producers to develop individual contingency plans to respond to a • Economic analysis of odour mitigation catastrophic event resulting in mass technologies for Manitoba conditions. mortalities.

11.1 The Manitoba government include 11.7 The Manitoba government enact biodiversity conservation considerations regulations under The Animal Diseases into its decision-making process Act to regulate the sale, use and regarding the expansion in the livestock disposal of drugs for animals. This sector or significant changes in land regulation should include the recording use. Policies should identify and respect of information on the drug types, critical regional wildlife habitats, volumes, length of treatment, classes of discourage the conversion of natural animals being treated, and purposes to habitats to serve as manure spread which these medications are being used. fields, and discourage the fertilization of This information should be compiled, native grasslands and prairies. analyzed, and reported to the public on a regular basis. 11.2 The Manitoba government identify ecologically sensitive sites (such as tall 11.8 The Manitoba government work and mixed grass prairie remnants) and with the federal government, other establish no-manure-application buffer provincial governments, and research zones around them. These zones should institutes to establish a comprehensive be established in consultation with eco- data collection network on antibiotic system specialists and hydrologists on a resistance in food animals. site-by-site basis. 11.9 The Manitoba government monitor 11.3 The Manitoba government increase the surface water for microbial resources of the Workplace Safety and contaminants, especially in regions Health Prevention Service Branch to with high concentrations of intensive provide for more inspection of hog- livestock operations. production operations. 11.10 The Manitoba government have hog 11.4 The Manitoba government take steps to manure examined for the presence of have a modified version of the National antibiotics and antibiotic resistant Farm Building Code apply in Manitoba bacteria. following consultation with concerned parties. 11.11 The Manitoba government facilitate, encourage, and undertake further studies 11.5 The Manitoba government take the lead into the efficacy and requirement for the in developing a contingency plan to use of antibiotic drugs in feed animals. address the animal welfare consequences of a border closing. The planning should 12.1 The Manitoba government adopt a new account for both border closings caused approval process for new, modified, and by a large-scale animal disease outbreak expanding manure storage-facilities and those that arise for reasons such as operations as detailed in Chapter 12. erection of trade barriers. Under this process, proponents would submit detailed site assessments that would be screened by a provincial

159 Manitoba Clean Environment Commission Technical Advisory Committee coordinated by Manitoba Conservation. The review process would produce a report that would be available to the public, along with the site assessment. This report, the site assessment, and the TAC comments, would go to the municipality and the local offices of relevant provincial departments. Responsibility for determining land- use issues would remain with the municipal authority, while the provincial government would retain responsibility for the issuance of environmental approvals.

13.1 Manitoba Conservation and Manitoba Agriculture, Food and Rural Initiatives develop a common database to record the presence of all Manitoba livestock operations.

13.2 The Manitoba government develop and publish a series of trend reports on the data that it collects and compiles on water quality, soil quality, air quality, and health issues related to the raising of livestock.

13.3 A Watershed Studies Institute be established to coordinate information collection, analysis, and evaluation, direct research and provide support to agencies and organizations undertaking watershed management in Manitoba.

160 Environmental Sustainability and Hog Production in Manitoba

15 Recommandations

9.1 Les dates de mise en place progressive sur l’application de phosphore du des dispositions relatives au phosphore Règlement sur la gestion des animaux du Règlement sur la gestion des animaux morts et des déjections du bétail cinq ans morts et des déjections du bétail devraient après l’entrée en vigueur de ce règlement. être ajustées afin que le plein respect de Cette révision devrait envisager : ce règlement, par tous les exploitants, soit atteint en 2013. • les tendances par région des niveaux de phosphore mesurés dans les sols;

9.2 L’interdiction d’épandre des déjections • l’efficacité des mesures d’exécution et le en hiver prévue par le Règlement sur respect du règlement; la gestion des animaux morts et des déjections du bétail devrait viser toutes les • les conséquences des quantités de exploitations agricoles d’ici 2013. phosphore mesurées dans les sols sur la qualité de l’eau et des cours d’eau 9.3 Le gouvernement du Manitoba devrait environnants; entreprendre une révision des dispositions

161 Manitoba Clean Environment Commission • l’évaluation de seuils; relatives au phosphore du Règlement sur la gestion des animaux morts et • l’évaluation des outils d’analyse des des déjections du bétail. Cela devrait risques; comprendre un financement pour la • l’évaluation des pratiques de gestion mise en place de pratiques de gestion employées pour réduire les risques agricole bénéfiques efficaces. environnementaux liés au phosphore. 9.7 Le gouvernement du Manitoba devrait Cette révision ne sera possible que s’il modifier le Règlement sur la gestion des existe une large gamme de données sur la animaux morts et des déjections du bétail qualité de l’eau. Il faudrait donc commencer afin que les nouvelles exploitations et immédiatement les efforts de surveillance celles qui s’agrandissent soient obligées de la qualité de l’eau requis pour obtenir ces de démontrer qu’elles disposent d’une données. superficie de terres cultivées suffisante pour que les taux d’application et d’élimination de phosphore puissent 9.4 Le gouvernement du Manitoba devrait s’équilibrer à long terme. immédiatement entreprendre, faciliter et commanditer des recherches sur le phosphore mesuré dans les sols et 9.8 Le gouvernement du Manitoba et les mécanismes de transport de cet l’industrie devraient encourager élément en vue de calculer un seuil de les producteurs à gérer les étables phosphore caractéristique des sols et et les installations de stockage de des conditions climatiques du Manitoba déjections de manière à maximiser et collaborer à de telles recherches. l’approvisionnement et les applications Ces recherches devraient comprendre au printemps et en été. l’examen de l’efficacité d’un index de phosphore pour le Manitoba. Ce seuil de 9.9 Le gouvernement du Manitoba devrait phosphore devrait être pris en compte faciliter, encourager et entreprendre des lors de la révision des dispositions études complémentaires sur les effets réglementaires sur le phosphore. cumulatifs de l’épandage de déjections sur les terres marginales. Cela devrait 9.5 Le gouvernement du Manitoba devrait inclure l’examen des mouvements et travailler en collaboration avec d’autres des transferts de pathogènes et du organismes afin de mettre au point ruissellement des nutriants. des pratiques de gestion agricole bénéfiques basées sur les connaissances 9.10 Le gouvernement du Manitoba devrait scientifiques, respectueuses de aider les producteurs dans leurs efforts l’environnement et économiquement à utiliser ou à concevoir des techniques viables afin de réduire les pertes de qui réduisent le volume de déjections phosphore par ruissellement de surface liquides. De telles mesures permettraient pour les sols, le paysage et le climat du de réduire le coût de transport des Manitoba. nutriants, ce qui rendrait l’utilisation des nutriants contenus dans les 9.6 Le gouvernement du Manitoba devrait déjections plus efficace et permettrait fournir aux éleveurs de bétail un appui de diminuer la pression à transformer financier ou mettre en place des mesures des terres naturelles en terres cultivées. incitatives afin d’aider les exploitants à se conformer aux dispositions 9.11 Le gouvernement du Manitoba devrait éliminer les différences terminologiques

162 Environmental Sustainability and Hog Production in Manitoba

(surtout en ce qui concerne les zones • l’incidence de maladies découlant de et les classifications) qui existent entre pathogènes et les liens qui existent le Règlement sur la gestion des animaux entre ces maladies et le secteur de morts et des déjections du bétail et le l’élevage; Règlement sur la gestion des nutriants. • les répercussions que les déjections 9.12 Le gouvernement du Manitoba devrait utilisées comme engrais peuvent avoir établir des bilans nutritifs pour les sur la faune, en particulier dans le cas régions agricoles du Manitoba à l’échelle des épandages en surface. des sous-bassins hydrographiques puis ultérieurement, à l’échelle des bassins 9.14 Le gouvernement du Manitoba devrait complets. faciliter, encourager et entreprendre des études complémentaires afin d’évaluer 9.13 Le gouvernement du Manitoba devrait la quantité de métaux lourds dans les faciliter, encourager et entreprendre terres agricoles du Manitoba et les effets des études complémentaires afin de potentiels que l’épandage de déjections déterminer : pourrait avoir sur l’environnement à long terme. • des pratiques et des technologies qui protègent davantage l’environnement, 9.15 Le gouvernement du Manitoba devrait les animaux et les humains de la exiger que toutes les nouvelles propagation de pathogènes issus installations de stockage des déjections d’exploitations porcines. Pour cela, en acier ou en béton construites au- il faudrait notamment déterminer le dessus du sol soient entourées d’une rôle joué par les limites d’azote et de digue permettant l’endiguement d’un phosphore gouvernant l’épandage de volume égal à 110 % de la capacité de déjection au Manitoba et étudier les l’installation de stockage. mécanismes de transfert; 9.16 Le gouvernement du Manitoba devrait • des pratiques et des technologies qui exiger que les exploitants d’installation permettent d’éliminer les pathogènes de stockage des déjections soient ou d’en réduire efficacement les accrédités d’une manière similaire quantités dans les déjections du à ce qui se fait pour les exploitants bétail au Manitoba. Pour cela, d’installations de traitement des eaux. il faudrait notamment effectuer De plus, les certificats visant les des recherches sur l’efficacité des installations de stockage des déjections installations de stockage à plusieurs devraient être valides pour cinq ans, bassins et chercher à savoir si tout comme ceux visant les installations le traitement des déjections du de traitement des eaux. bétail avec de l’ammoniaque ou de l’urée permettrait, dans le contexte 9.17 Les installations de stockage des manitobain, d’éliminer les pathogènes déjections en béton ou en acier des déjections; devraient être inspectées tous les • les risques auxquels sont confrontées trois ans par un ingénieur ou une les personnes qui travaillent dans ingénieure des structures qualifié. des exploitations porcines en raison de la présence de pathogènes et les 9.18 Le gouvernement du Manitoba devrait mesures qui peuvent être prises pour faciliter, encourager et entreprendre des éliminer ou réduire ces risques; études complémentaires sur la migration

163 Manitoba Clean Environment Commission des déjections liquides dans les sols vers 9.24 Le gouvernement du Manitoba devrait les aquifères et sur les conséquences obtenir des données précises sur que cela pourrait avoir à long terme sur les sources d’eau employées pour le les ressources en eau souterraines. bétail, leur qualité et leur utilisation. Cela consisterait notamment à faire 9.19 Il faudrait uniformiser les dispositions une lecture des compteurs dans les du Règlement sur la gestion des animaux exploitations d’élevage par les agents morts et des déjections du bétail avec de l’environnement du ministère celles du Technical Reference Manual au moment de l’inspection des for Liquid Manure Storage Structures installations de stockage des déjections, (manuel de référence technique pour les une comparaison des lectures de structures de stockage des déjections compteurs avec les quantités allouées liquides). et une publication de résumés annuels comparant la consommation d’eau aux 9.20 Le gouvernement du Manitoba quantités allouées pour chaque secteur. devrait signaler tous les changements importants quant à la conception des 9.25 Le gouvernement du Manitoba devrait installations de stockage des déjections compiler des renseignements sur les aux autorités municipales compétentes. technologies qui permettent de réduire l’utilisation d’eau sans compromettre 9.21 Le gouvernement du Manitoba devrait la performance des animaux et mettre maintenir sa politique consistant à ces renseignements à la disposition des envoyer ses agents de l’environnement producteurs. effectuer des inspections des installations de stockage des déjections 9.26 Le gouvernement du Manitoba devrait visées par un permis sur une base faciliter, encourager et entreprendre des annuelle, en donnant la priorité aux études complémentaires sur l’utilisation exploitations à haut risque. de l’eau, le gaspillage d’eau et les technologies et les pratiques permettant 9.22 Le gouvernement du Manitoba devrait de réduire la consommation d’eau. Ces exiger que toutes les nouvelles études devraient notamment porter sur : exploitations porcines et toutes celles qui sont modifiées ou agrandies soient • l’utilisation de l’eau en fonction du tenues de déposer des plans de gestion génotype, de la phase de production, des déjections. de l’environnement et de la santé de l’animal;

9.23 Le gouvernement du Manitoba devrait • les quantités d’eau utilisées dans les s’assurer que le ministère de la exploitations porcines n’ayant pas de Conservation dispose de ressources compteur d’eau; suffisantes pour évaluer les propositions d’exploitations porcines, pour inspecter • les stratégies de gestion des animaux les exploitations existantes sur une base et la conception des bâtiments annuelle, pour vérifier 10 % des plans d’élevage qui minimisent l’utilisation de gestion des déjections annuellement, et le gaspillage d’eau et permettent pour enregistrer les installations de par conséquent de réduire le volume stockage des déjections non encore de déjections; autorisées et pour mettre en application la réglementation existante sur la • le recyclage des eaux usées pour gestion des déjections. les exploitations existantes qui ne

164 Environmental Sustainability and Hog Production in Manitoba

pourraient pas réduire de manière agricoles basée sur les théories de significative leur utilisation d’eau en dispersion des odeurs. Une telle ligne raison de problèmes de conception; directrice prendrait en considération les divers facteurs qui jouent un rôle • les rations alimentaires qui dans l’émission et la dispersion des minimisent les nutriants excédentaires odeurs, y compris la topographie et la et les apports de minéraux, ce qui technologie. peut par conséquent jouer sur l’apport d’eau et la production de déjections. 10.7 Le gouvernement du Manitoba devrait faciliter et encourager les recherches et 10.1 Le gouvernement du Manitoba devrait la collecte de données, et y collaborer, exiger que toutes les nouvelles dans les domaines suivants : installations de stockage des déjections soient recouvertes d’une couverture en • les normes et les procédures pour matière synthétique (idéalement d’une mesurer les émissions olfactives couverture à pression négative). provenant des étables et des installations de stockage des 10.2 Le gouvernement du Manitoba devrait déjections au Manitoba; exiger que toutes les nouvelles exploitations et que celles qui • les effets potentiels sur la santé des s’agrandissent injectent les déjections odeurs provenant des exploitations du bétail ou les incorporent dans les porcines dans les zones situées sols dans les 48 heures après l’épandage. en aval des exploitations dans la direction du vent. Ces renseignements 10.3 La Commission de protection des sont indispensables pour établir pratiques agricoles ne devrait plus des critères valables d’exposition réclamer un dépôt de 50 $ aux acceptable aux odeurs dans les plaignants lorsqu’ils déposent une collectivités; plainte. • les taux d’émission et les caractéristiques des odeurs provenant 10.4 Les agents de l’environnement du des exploitations porcines; ministère de la Conservation du Manitoba devraient être autorisés à • la distribution des odeurs et des faire respecter les ordonnances de la autres contaminants atmosphériques Commission de protection des pratiques en aval des exploitations dans la agricoles en vertu des pouvoirs qui direction du vent; leurs sont conférés par la Loi sur l’environnement. • l’analyse économique des technologies d’atténuation des odeurs 10.5 Le budget de la Commission de pour les conditions du Manitoba. protection des pratiques agricoles devrait être augmenté afin de lui 11.1 Le gouvernement du Manitoba devrait permettre d’entreprendre plus d’actions envisager la conservation de la pour faire connaître les services qu’elle biodiversité dans son processus de prise offre au public. de décision relatif à l’expansion du secteur de l’élevage ou à un changement 10.6 Le gouvernement du Manitoba devrait significatif d’une utilisation des mettre en place une ligne directrice terres. Les politiques devraient définir sur les odeurs des exploitations et respecter les habitats fauniques

165 Manitoba Clean Environment Commission régionaux critiques et décourager catastrophiques entrainant une mortalité la conversion d’habitats naturels en massive. champs d’épandage de déjections ainsi que la fertilisation des surfaces 11.7 Le gouvernement du Manitoba pastorales et des prairies indigènes. devrait promulguer des règlements en application de la Loi sur les maladies 11.2 Le gouvernement du Manitoba devrait des animaux afin de réglementer la définir les sites écosensibles (comme vente, l’utilisation et l’élimination les vestiges de prairie à herbes hautes des médicaments pour les animaux. et de prairie mixte) et établir des Ce règlement devrait prévoir que le zones tampon autour de ces sites où il type et les volumes de médicament serait interdit de faire des applications utilisés, les durées de traitement, les de déjections. Ces zones devraient classes d’animaux traités et les raisons être établies en consultation avec des pour lesquelles ces médicaments spécialistes des écosystèmes et des ont été utilisés soient consignés. hydrologues, au cas par cas. Ces renseignements devraient être rassemblés et analysés régulièrement et 11.3 Le gouvernement du Manitoba devrait présentés au public. accroître les ressources de la Direction des services de prévention de la Division 11.8 Le gouvernement du Manitoba devrait de la sécurité et de l’hygiène du travail travailler avec le gouvernement fédéral, afin qu’elle puisse effectuer plus les autres gouvernements provinciaux et d’inspections d’exploitations porcines. des instituts de recherche afin d’établir un réseau de collecte de données étendu 11.4 Le gouvernement du Manitoba devrait sur la résistance aux antibiotiques des prendre des mesures pour qu’une animaux destinés à l’alimentation. version modifiée du Code national de construction des bâtiments agricoles 11.9 Le gouvernement du Manitoba devrait soit appliquée au Manitoba suite à surveiller la composition microbienne des consultations avec les parties des eaux de surface pour détecter concernées. d’éventuels contaminants, surtout dans les régions où il y a une grande 11.5 Le gouvernement du Manitoba devrait concentration d’exploitations porcines diriger l’élaboration d’un plan de secours intensives. pour faire face aux conséquences qu’entrainerait une fermeture de la 11.10 Le gouvernement du Manitoba devrait frontière avec les États-Unis pour le faire examiner la composition des bien-être des animaux. La planification déjections porcines afin de détecter la devrait envisager non seulement les présence d’antibiotiques et de bactéries fermetures de frontière motivées par une résistantes aux antibiotiques. épidémie animale à grande échelle, mais aussi par la volonté de créer un obstacle 11.11 Le gouvernement du Manitoba devrait au commerce. faciliter, encourager et entreprendre des études complémentaires sur l’efficacité 11.6 Le gouvernement du Manitoba devrait des antibiotiques chez les animaux travailler avec les producteurs pour destinés à l’alimentation et sur les élaborer des plans de secours individuels exigences quant à leur utilisation. afin de répondre à des situations

166 Environmental Sustainability and Hog Production in Manitoba

12.1 Le gouvernement du Manitoba devrait d’offrir un soutien aux agences et aux adopter un nouveau processus organismes qui s’occupent de la gestion d’agrément pour la mise en service des de bassins hydrologiques au Manitoba. nouvelles installations de stockage des déjections et de celles qui sont modifiées ou agrandies, comme l’explique en détail le chapitre 12. Selon ce processus, les promoteurs devraient déposer une évaluation détaillée du site qui serait examinée par un comité consultatif technique provincial coordonné par Conservation Manitoba. Le processus de révision aboutirait à la préparation d’un rapport qui serait mis à la disposition du public, tout comme l’évaluation du site. Ce rapport, l’évaluation du site et les commentaires du comité consultatif technique seraient transmis à la municipalité et aux bureaux régionaux des ministères provinciaux concernés. Les administrations municipales conserveraient la responsabilité de trancher sur les questions liées à l’utilisation des terres et le gouvernement provincial garderait le pouvoir de délivrer les autorisations environnementales.

13.1 Conservation Manitoba et Agriculture, Alimentation et Initiatives rurales Manitoba devraient mettre en place une base de données commune pour enregistrer toutes les exploitations d’élevage qui existent au Manitoba.

13.2 Le gouvernement du Manitoba devrait concevoir et publier une série de rapports de tendances à partir des données qu’il recueille et rassemble sur la qualité de l’eau, des sols et de l’air et sur les questions de santé liées au secteur de l’élevage.

13.3 Un institut de recherche sur les bassins hydrologiques devrait être mis en place afin de coordonner la collecte de renseignements, les analyses, les évaluations et les recherches directes et

167 Manitoba Clean Environment Commission

168 References

Advisory Committee on Animal Uses of Audubon. n.d. Common Birds in Decline. Antimicrobials and Impact on Resistance http://www.stateofthebirds.audubon.org/ and Human Health. 2002. Uses of cbid/ accessed November 15, 2007. antimicrobials in food Animals in Canada: Benjamin, Gary. 1997. Industrialization in Impact on resistance and human health. hog production: implications for Midwest Veterinary Drugs Directorate. Ottawa: agriculture. Economic Perspectives Health Canada. January:2-13. Agriculture and Agri-Food Canada. 2001. Brewin, Derek, Janet Honey, and James Agriculture in Harmony with Nature: Ryan. 2007. Statistics for Manitoba Pig Agriculture and Agri-Food Canada’s Industry. In D. Flaten, K.Wittenberg, and Sustainable Development Strategy, 2001- Q. Zhang. A report on current knowledge 2004. Ottawa. of key environmental issues related to hog Auditor General Manitoba. 2007. Audit of the production in Manitoba. Commissioned Department of Conservation’s Management by the Manitoba Clean Environment of the Environmental Livestock Program. Commission. Winnipeg: Auditor General of Manitoba.

169 Manitoba Clean Environment Commission Broadway. Michael J. 2006, Pigs on the Flaten, D., K.Wittenberg, and Q. Zhang. prairies. The Geographical Review A report on current knowledge of key 96(1):122-138. environmental issues related to hog Bureau d’audiences publiques sur production in Manitoba. Commissioned l’environnement. L’inscription de la by the Manitoba Clean Environment production porcine dans le développement Commission. durable. Consultation publique sur le Fowke, Vernon. 1957. The National Policy and développement durable de la production the Wheat Economy. Toronto: University porcine au Québec. Rapport principal. of Toronto Press. Rapport 179. Septembre 2003. Gibbon, David, Alex Lake, Michael Stocking. Cole, Dana, Lori Todd and Steve Wing. 1995. Sustainable development: a 2000. Concentrated swine feeding challenge for agriculture. In People and operations and public health: A review the Environment. Stephen Morse and of occupational and community health Michael Stocking (eds). Vancouver: effects environment. Mental Health University of British Columbia Press. Perspectives 108(8):685-699 Government of Canada. 2000. Regulations Commissioner of the Environment and respecting the making of medicated Sustainable Development. 2005. Report feed. http://canadagazette.gc.ca/ to Parliament on the environmental partI/2000/20000205/html/regle1-e. petitions process as required by the html accessed September 19, 2007. Auditor General Act. http://www.oag- Grier, Kevin, Cher Brethour, Beth Sparling, bvg.gc.ca/domino/reports.nsf/html/ and Al Mussell. 2007, Economic c20050908ce.html accessed May 31, Analysis of the Hog Production Industry 2007. in Manitoba in Relation to the Clean Constance, Douglas H. and Alessandro Environment Commission Review of Bonanno. 1999. CAFO controversy Environmental Sustainability. Guelph: in the Texas Panhandle region: The George Morris Centre. Commissioned environmental crisis of hog production. by the Manitoba Clean Environment Culture and Agriculture 21(1):14-26. Commission. Donham, Kelley J. and Anders Thelin. 2006. Haley, Mildred M. 2004. Market integration Agricultural medicine: occupational and in the North American hog industries. environmental health for the health United States Department of Agriculture, professions. Ames, Iowa: Blackwell Press. LDP-M-125-01, November. Environment Canada. 1995. Canadian Hamann, Karen. 2006. An overview of Biodiversity Strategy: Canada’s response Danish pork industry: Integration and to the Convention on Biological Diversity. structure. Advances in Pork Production Ottawa: Minister of Supply and Services 17, 93-97. Canada. Harris, D.L. 2000. Multi-site pig production. Environment Canada. 2006. Recovery Ames: Iowa State University Press. Strategy for the Western Prairie Fringed Holley, Richard A., Mignon Marcaida, Orchid (Platanthera praeclara) in Canada and Denis Krause. 2007. Pathogens Species at Risk Act Recovery Strategy and antibiotic resistance. In D. Series. Ottawa: Environment Canada, Flaten, K.Wittenberg, and Q. Zhang. V+22. A report on current knowledge of key Environment Canada. 2007. National environmental issues related to hog Inventory Report 1990–2005: Greenhouse production in Manitoba. Commissioned Gas Sources and Sinks in Canada Annual by the Manitoba Clean Environment 1990/2005. Ottawa: Environment Commission. Canada.

170 Environmental Sustainability and Hog Production in Manitoba

Honey, Janet, and Brian Oleson. 2006. A Manitoba Government. 2000a. Livestock century of agriculture in Manitoba. Stewardship 2000: A public discussion Winnipeg: Credit Union Central of paper. Winnipeg: Government of Manitoba. Manitoba. Irwin, Lindsay. 2007. Hog Production in Manitoba Government. 2000b. Technical Manitoba: Public Perceptions of the Review Committee Process for Livestock Industry’s Environmental Sustainability. Operations Terms of Reference. Natural Resources Institute. University Winnipeg: Government of Manitoba. of Manitoba. Manitoba Government. 2006. An Examination Khachatourians, George G. 1998. Agricultural of the Environmental Sustainability of use of antibiotics and the evolution and the Hog Industry in Manitoba. Winnipeg: transfer of antibiotic-resistant bacteria. Government of Manitoba. Canadian Medical Association Journal Manitoba Government. 2007a. Farm Practices 159:1129-36. Guidelines for Pig Producers in Manitoba. Khanna, T., R. Friendship, C. Dewey, Manitoba Government. 2007b. Manitoba and J.S. Weese. 2007. Methicillin Soil Fertility Guide 2007. Winnipeg: resistant Staphylococcus aureus Government of Manitoba. colonization in pigs and pig farmers. Manitoba Phosphorus Expert Committee. Veterinary Microbiology 10.1016/j. 2006. Recommendations for Regulation vetmic.2007.10.006 Phosphorus From Livestock Operations Lake Winnipeg Stewardship Board. 2007. in Manitoba. Winnipeg: Manitoba Reducing Nutrient Loading to Lake Phosphorus Expert Committee. Winnipeg: Winnipeg and Its Watershed. Winnipeg. Government of Manitoba. Legislative Review Committee on The Workers Manitoba Pork Council. n.d. How pigs are Compensation Act. 2005. Working for raised. Winnipeg: Manitoba Pork Council. Manitoba: Workers compensation for Manitoba Pork Study Committee. 1994. the twenty-first century report of the Manitoba’s pork industry: Building for Legislative Review Committee on The the 21st century prospects and challenges. Workers Compensation Act. Winnipeg: Winnipeg: Government of Manitoba. Government of Manitoba. Mann, J. and C. Grant. 2006. Economic Levy, Stuart. 1998. Multidrug resistance—A assessment of manure phosphorus sign of the times. New England Journal regulations for Manitoba’s pig industry: of Medicine 338:1376-1378. Part 2 - Overall impact at the provincial Livestock Stewardship Panel. 2000. Finding scale. A report to the Manitoba Livestock Common Ground. Winnipeg: Government Manure Management Initiative. of Manitoba. Winnipeg. Manitoba Clean Environment Commission. McBride, W. D. and Nigel Key. 2003. 1979. Report of an investigation Economic and structural relationships in of intensive livestock operations in U.S. hog production, resource economics Manitoba. Winnipeg: Government of division. Economic Research Service, U.S. Manitoba Department of Agriculture. Agricultural Manitoba Conservation. n.d. Conservation Economic Report No. 818. Data Centre http://web2.gov.mb.ca/ McBride, W.D. 1997. The role of changing conservation/cdc vertical coordination in the pork Manitoba Government. 1978. Environmental and broiler Industries. Agricultural problems associated with the livestock Economics Report No. 777. Washington, industry in Manitoba. Winnipeg: D.C.: Economic Research Service, U.S. Government of Manitoba. Department of Agriculture.

171 Manitoba Clean Environment Commission McGeer, Allison. 1998. Agricultural Production Industry Review. Winnipeg antibiotics and resistance in human International Institute for Sustainable pathogens: Villain or scapegoat? Development. Commissioned by Canadian Medical Journal 159(9):1119- the Manitoba Clean Environment 1120. Commission. McLaughlin, Alison and Pierre Mineau. 1995. Oenema, O. and Paul Berentsen. 2005. The impact of agricultural practices on Manure Policy and MINAS: Regulating biodiversity. Agriculture, Ecosystems and nitrogen and phosphorus surpluses in Environment 55:201-212. agriculture in the Netherlands. Paris: McMillan, R.J. R.N. Betcher, and A.D. Organization for Economic Cooperation Woodbury. 2001. Studies of seepage and Development. beneath earthen manure storages and Oenema, O. 2004. Governmental policies cattle pens in Manitoba. http://www. and measures regulating nitrogen and gov.mb.ca/agriculture/livestock/ phosphorus from animal manure in livestockopt/tc.html. Accessed October European agriculture. Journal of Animal 24, 2007. Science 82(E. Supplement):196-206. Moyer, Paul. 2006. Dutch search and destroy Ominski, K., M. Tenuta, D. Krause, D. policy keeps community-acquired Flaten, K. Wittenberg, R. Holley, M. MRSA in check. Medscape Medical News Entz, C. Wilson, D. Tremorin, and September 6. J. Walkty. 2007. Best management Naylor, Rosamond, Henning Steinfeld, Walter practices to improve the productivity Falcon, James Galloway, Vaclav Smil, and environmental sustainability of Erica Bradford, Jackie Alder, Harold grassland pasture systems. Final Report. Mooney. 2005. Losing the links between University of Manitoba, Winnipeg. livestock and land. Science. 310(9):1621- Unpublished. 1622. Racz, G.J. and M.M. Fitzgerald. 2001. Nicolas Jr., Leo, Doug Small, Geza Racz, Nutrient and heavy metal contents of David Abbot, Dennis Hodgkinson, hog manure: Effect on soil quality and Charles Lui, and Gary Warkentine. 2002. productivity. Paper presented at the Study of regional nutrient balances in Livestock Options for the Future. June four municipalities in Manitoba. DGH 25-27, 2001. Winnipeg. Engineering. Rawluk, Christine and Don Flaten, 2007. Novek, Joel. 2003. Intensive livestock Manure management and water quality. operations, disembedding, and In D. Flaten, K.Wittenberg, and Q. community polarization in Manitoba. Zhang. A report on current knowledge of Society and Natural Resources 16(7):567- key environmental issues related to hog 581. production in Manitoba. Commissioned Nyatchoti, Martin, Laurie Connor, and Elijah by the Manitoba Clean Environment Kiarie. 2007. Water Use by Manitoba Pig Commission. Operations. In D. Flaten, K.Wittenberg, Rhodes, V. James. 1995. The and Q. Zhang. A report on current Industrialization of Hog Production. knowledge of key environmental issues Review of Agricultural Economics related to hog production in Manitoba. 17(2):07-118. Commissioned by the Manitoba Clean Ribaudo, Marc. 2003. Managing manure: Environment Commission. New Clean Water Act regulations create Oborne, Bryan, Henry David Venema and imperative for livestock producers. Allan Tyrchniewicz. 2007. Research Amber Waves 1(1). in support of the Manitoba Clean Richard, T. L. and C. C. Hinrichs. 2002. Environment Commission’s Hog Management and maintenance of

172 Environmental Sustainability and Hog Production in Manitoba

earthen manure structures: implications Tyrchniewicz, Ed and Heather Gregory. 2003. and opportunities for water quality Manitoba’s Pork Value Chain: Where is protection. Applied Engineering in it Going and What is Driving it? Report Agriculture 18(6):727–734. prepared for Market and Industry The Royal Society. 2004. Infectious disease Services Branch of Agriculture and in livestock follow up review. London: The Agrifood Canada, Winnipeg Royal Society. Voss, Andreas, Frans Loeffen, Judith Bakker, Ryan, John. 1977. The agricultural economy Corne Klaassen, and Mireille Wulf. 2005. of Manitoba Hutterite colonies. Toronto: Methicillin-resistant staphylococcus McClelland and Stewart. aureus in pig farming. Emerging Salvano, E., D. Flaten, C. Grant, and G. Infectious Diseases 11(12):1965-1966. Johnson. 2006. Economic assessment Wedin, D. A. and D. Tilman. 1996. Influence of manure phosphorus regulations for of nitrogen loading and species Manitoba’s pig industry: Part 1 - Costs composition on the carbon balance of alternative manure management of grasslands. Science 274:1720-1723. strategies. A report to the Manitoba (Highlighted in Science Environment Livestock Manure Management Initiative. 274:1610-1611 by J. Kaiser, and The New Winnipeg. York Times December 10, 1996.) Shea, Katherine M. and the Committee on Whiting, T.L. 2003. Foreign animal Environmental Health and Committee disease outbreaks, the animal welfare on Infectious Diseases. 2004. implications for Canada: Risks apparent Nontherapeutic use of antimicrobial from international experience. Canadian agents in animal agriculture: Veterinary Journal 44:805–815. Implications for pediatrics. Pediatrics Whiting, T.L. 2006. Welfare slaughter of 114(3):862-868. livestock in emergency situations. Sheppard, Andrew. 2002. The Structure of Canadian Veterinary Journal 47:737. Pig Production in England. University of Whiting, T.L. n.d. Special welfare concerns Exeter Centre for Rural Research. for countries dependent on live animal Smil, Vaclav. 2000. Feeding the world: a trade: the real foreign animal disease challenge for the twenty-first century. emergency for Canada. Cambridge, Mass.: MIT Press. Wilson, J. 1975. Lisoway, Michael and Steinfeld, P., Gerber, T. Wassenaar, V. Castel, Lisoway, Caroline and Springfield Hog M. Rosales, C. de Haan. 2006. Livestock’s Ranch. Queen’s Bench 24 November. long shadow: Environmental issues and Wilson, Scott D. and Joyce W. Belcher. options. Rome: Food and Agriculture 1989. Plant and bird communities of Organization of the United Nations. native prairie and introduced Eurasian Statistics Canada. 2006. 2006 Census of vegetation in Manitoba. Canada Agriculture. http://www.statscan.ca/ Conservation Biology 3(1):39-44. english/agcensus2006/index.htm Wittenberg, Karin and Dina Boadi. 2001. Tilman, David, Kenneth G. Cassman, Pamela Reducing greenhouse gas emissions A. Matson, Rosamond Naylor and from livestock agriculture in Manitoba. Stephen Polasky. 2002. Agricultural Winnipeg: Manitoba Climate Change Task sustainability and intensive production Force. practices. Nature 418:671-677. World Health Organization. 2006. Tyrchniewicz, Allen and Art Wilson. 1995. Constitution of the World Health Agriculture and Sustainable Development: Organization. Basic Documents, Forty- Policy Analysis on the Great Plains, fifth edition, Supplement. Winnipeg: International Institute for World Health Organization. 1986. Ottawa Sustainable Development. Charter for Health Promotion.

173 Manitoba Clean Environment Commission Wuethrich, Bernice. 2004. Chasing the fickle swine flu. Science 299:1502-1505 Zhang, Q., G. Qu, and R. York. 2007. Odour management and air quality. In D. Flaten, K.Wittenberg, and Q. Zhang. A report on current knowledge of key environmental issues related to hog production in Manitoba. Commissioned by the Manitoba Clean Environment Commission.

174 Appendix 1

Principles and Guidelines for 3(4) Manitobans should consider the Sustainable Development aspirations, needs and views of the people of the various geographical regions and Principles ethnic groups in Manitoba, including aboriginal peoples, to facilitate equitable 1. Integration of Environmental and management of Manitoba’s common Economic Decisions resources. 1(1) Economic decisions should adequately reflect environmental, human health and 4 Prevention social effects. Manitobans should anticipate, and prevent or mitigate, significant adverse economic, 1(2) Environmental and health initiatives environmental, human health and social should adequately take into account effects of decisions and actions, having economic, human health and social particular careful regard to decisions whose consequences. impacts are not entirely certain but which, on reasonable and well-informed grounds, appear 2 Stewardship to pose serious threats to the economy, the environment, human health and social well- 2(1) The economy, the environment, human being. health and social well-being should be managed for the equal benefit of present 5 Conservation and Enhancement and future generations. Manitobans should 2(2) Manitobans are caretakers of the (a) maintain the ecological processes, economy, the environment, human health biological diversity and life-support and social well-being for the benefit of systems of the environment; present and future generations. (b) harvest renewable resources on a 2(3) Today’s decisions are to be balanced with sustainable yield basis; tomorrow’s effects. (c) make wise and efficient use of renewable and non-renewable resources; and 3 Shared Responsibility and Understanding 3(1) Manitobans should acknowledge (d) enhance the long-term productive responsibility for sustaining the economy, capability, quality and capacity of natural the environment, human health and social ecosystems. well-being, with each being accountable for decisions and actions in a spirit of partnership and open cooperation. 6 Rehabilitation and Reclamation Manitobans should 3(2) Manitobans share a common economic, (a) endeavour to repair damage to or physical and social environment. degradation of the environment; and 3(3) Manitobans should understand and (b) consider the need for rehabilitation respect differing economic and social and reclamation in future decisions and views, values, traditions and aspirations. actions.

175 Manitoba Clean Environment Commission 7 Global Responsibility (b) promoting the opportunity for equal Manitobans should think globally and timely access to information by all when acting locally, recognizing that Manitobans. there is economic, ecological and social interdependence among provinces and 4 Integrated Decision Making and Planning nations, and working cooperatively, within - which means encouraging and Canada and internationally, to integrate facilitating decision making and planning economic, environmental, human health processes that are efficient, timely, and social factors in decision-making while accountable and cross-sectoral and which developing comprehensive and equitable incorporate an inter-generational perspective solutions to problems. of future needs and consequences. Guidelines 5 Waste Minimization and Substitution - 1 Efficient Use of Resources - which means which means (a) encouraging and facilitating development (a) encouraging and promoting the and application of systems for proper development and use of substitutes for resource pricing, demand management scarce resources where such substitutes and resource allocation together with are both environmentally sound and incentives to encourage efficient use of economically viable; and resources; and (b) reducing, reusing, recycling and (b) employing full-cost accounting to recovering the products of society. provide better information for decision makers. 6 Research and Innovation - which means encouraging and assisting 2 Public Participation - which means the researching, development, application (a) establishing forums which and sharing of knowledge and technologies encourage and provide opportunity which further our economic, environmental, for consultation and meaningful human health and social well-being. participation in decision making processes by Manitobans;

(b) endeavouring to provide due process, prior notification and appropriate and timely redress for those adversely affected by decisions and actions; and

(c) striving to achieve consensus amongst citizens with regard to decisions affecting them.

3 Access to Information - which means (a) encouraging and facilitating the improvement and refinement of economic, environmental, human health and social information; and

176 Appendix 2 (VJEF
UP
1VCMJD
1BSUJDJQBUJPO
JO
UIF
$MFBO
&OWJSPONFOU
$PNNJTTJPO
)PH
1SPEVDUJPO
*OEVTUSZ
3FWJFX

4HEINVESTIGATION IN THE VARIOUS REGIONS OF -ANITOBA TO ENSURE BROADPARTICIPATIONFROMTHEGENERALPUBLICAND /N.OVEMBER -ANITOBA#ONSERVATION AFFECTEDSTAKEHOLDERS -INISTER3TAN3TRUTHERSINSTRUCTEDTHE-ANITOBA #LEAN %NVIRONMENT #OMMISSION TO CONDUCT  4HE #%# INVESTIGATION SHOULD INCLUDE A AN INVESTIGATION INTO THE ENVIRONMENTAL REVIEWOFTHECONTENTSOFTHEREPORTPREPAREDBY SUSTAINABILITY OF HOG PRODUCTION IN -ANITOBA &ORTHISPURPOSE THE#%#WASASKEDTOCONDUCT -ANITOBA#ONSERVATIONENTITLEDh!N%XAMINATION PUBLIC MEETINGS AND PROVIDE ADVICE AND OFTHE%NVIRONMENTAL3USTAINABILITYOFTHE(OG RECOMMENDATIONSTOTHE-INISTER4HE-INISTER )NDUSTRYIN-ANITOBAv PROVIDED THE FOLLOWING TERMS OF REFERENCE FOR THEINVESTIGATION 4HE#%#WILL ASPARTOFTHISINVESTIGATION TAKEINTOACCOUNTTHEEFFORTSUNDERWAYINOTHER 4HE#%# ASAPARTOFITSINVESTIGATIONWILL JURISDICTIONS TO MANAGE HOG PRODUCTION IN A REVIEW THE CURRENT ENVIRONMENTAL PROTECTION SUSTAINABLEMANNER MEASURESNOWINPLACERELATINGTOHOGPRODUCTION IN -ANITOBA IN ORDER TO DETERMINE THEIR  !S PART OF ITS INVESTIGATION AND BASED ON EFFECTIVENESSFORTHEPURPOSEOFMANAGINGHOG PUBLICFEEDBACK THECOMMISSIONWILLCONSIDER PRODUCTION IN AN ENVIRONMENTALLY SUSTAINABLE VARIOUSOPTIONSANDMAKERECOMMENDATIONSIN MANNER AREPORTTOTHE-INISTERONANYIMPROVEMENTS THAT MAY BE NECESSARY TO PROVIDE FOR THE 4HE#%#INVESTIGATIONMUSTINCLUDEAPUBLIC ENVIRONMENTALSUSTAINABILITYOFHOGPRODUCTION COMPONENT TO GAIN ADVICE AND FEEDBACK FROM IN-ANITOBA -ANITOBANS 4HIS PUBLIC COMPONENT SHOULD BE CONDUCTED BY MEANS OF PUBLIC MEETINGS

177 Manitoba Clean Environment Commission 4HE#LEAN%NVIRONMENT RELATIONSHIP OF ECONOMIC ENVIRONMENTAL SOCIAL AND HUMAN HEALTH DECISION MAKING #OMMISSION RECOGNIZING THAT THE DECISIONS MADE IN ONE SPHERE HAVE IMPACTS ON THE OTHERS 7HILE 4HE #LEAN %NVIRONMENT #OMMISSION IS AN THE FOCUS OF THIS INVESTIGATION WILL BE ON ARMS LENGTH PROVINCIAL AGENCY ESTABLISHED THE IMPACT THAT HOG PRODUCTION HAS ON THE UNDER 4HE %NVIRONMENT !CT OF -ANITOBA SUSTAINABILITY OF THE -ANITOBA ENVIRONMENT 4HE #OMMISSION ENCOURAGES AND FACILITATES THE #OMMISSION WILL INTEGRATE ECONOMIC PUBLICINVOLVEMENTINENVIRONMENTALMATTERS HUMAN HEALTH AND SOCIAL FACTORS IN ITS AND OFFERS ADVICE AND RECOMMENDATIONS TO ANALYSISANDRECOMMENDATIONS THE -INISTER OF #ONSERVATION WITH RESPECT TO ENVIRONMENTAL ISSUES PROJECT APPROVALS AND ENVIRONMENTAL LICENSES ! THREE PERSON 0UBLICMEETINGS PANEL HAS BEEN STRUCK TO CARRY OUT THE HOG PRODUCTION INVESTIGATION 4HE 0ANEL IS BEING 4HETERMSOFREFERENCESOFTHISINVESTIGATION CHAIREDBY#%##HAIRPERSON4ERRY3ARGEANT CALL ON THE #OMMISSION TO CONDUCT PUBLIC MEETINGS IN THE VARIOUS REGIONS OF -ANITOBA TOENSUREBROADPARTICIPATIONFROMTHEGENERAL 0UBLICINPUTONTHESCOPEOF PUBLIC AND AFFECTED STAKEHOLDERS 4HOSE THEINVESTIGATION MEETINGS WILL BE HELD IN -ARCH AND !PRIL OF  4O ASSIST IN DElNING THE SCOPE OF THE 4HEMEETINGSWILLBEOPENTOALLMEMBERSOFTHE INVESTIGATION THE#OMMISSIONHELDTHREEDAYS PUBLICINCLUDINGPRESENTERS OBSERVERSANDTHE OF MEETINGS IN *ANUARY  IN &RIEDENSFELD MEDIA4HOSEWHOWISHTOMAKEPRESENTATIONS IN SOUTH EASTERN -ANITOBA 7INNIPEG ARE INVITED TO REGISTER WITH THE #OMMISSION AND -ORDEN IN SOUTH CENTRAL -ANITOBA  ! SEVEN DAYSBEFORETHECOMMUNITYSESSION WIDE RANGE OF INDIVIDUALS AND ORGANIZATIONS AT WHICH THEY WISH TO APPEAR 3HOULD TIME MADE PRESENTATIONS AT THESE MEETINGS BOTH ALLOW INDIVIDUALSWHOREGISTERATTHEHEARING IDENTIFYING ISSUES THEY BELIEVED SHOULD BE MAYALSOMAKEPRESENTATIONS4HOSEWHOWISH EITHERWITHINOROUTSIDEOFTHISSCOPEOFTHIS TOREGISTERSHOULDCONSULTTHEWEBSITEWWW INVESTIGATIONANDIDENTIFYINGSPECIlCCONCERNS CECMANITOBACA OR CONTACT THE #OMMISSION WITHHOGPRODUCTIONIN-ANITOBA DIRECTLY AT    OR    TOLL FREE NUMBER FOR RURAL RESIDENTS  0RESENTATIONS WILL BE LIMITED TO  MINUTES 4HESCOPEOFTHE UNLESS PRIOR ARRANGEMENTS HAVE BEEN MADE INVESTIGATION WITH THE #OMMISSION 3ECRETARY 0RESENTERS MAYAPPEARONLYONCEBEFORETHE0ANELDURING 4HE#LEAN%NVIRONMENT#OMMISSIONSWORKIS THESEMEETINGS7RITTENSUBMISSIONSAREALSO SHAPEDBY4HE%NVIRONMENT!CTOF-ANITOBAANDOF-ANITOBAAND ACCEPTED THEDEADLINEFORTHESESUBMISSIONS 4HE3USTAINABLE$EVELOPMENT!CTOF-ANITOBA IS-AY  $RAWING ON THE DElNITIONS IN THOSE !CTS IT INTERPRETS THE FOCUS OF THIS )NVESTIGATION )N KEEPING WITH THE PROVISIONS OF 4HE TO BE AN INQUIRY INTO THE IMPACT OF THE %VIDENCE!CTMEMBERSOFTHEPUBLICWHOMAKEMEMBERSOFTHEPUBLICWHOMAKE HOG PRODUCTION INDUSTRY ON THE INDElNITE PRESENTATIONSATTHESEMEETINGSWILLBESWORN SUSTAINABILITY OF -ANITOBAS PHYSICAL AND IN 7HILE THE 0ANEL MEMBERS WILL QUESTION BIOLOGICAL WORLD 4HE #OMMISSION ALSO NOTES PRESENTERS THERE WILL BE NO PROVISION FOR THAT-ANITOBAS0RINCIPLESAND'UIDELINESFOR MEMBERS OF THE PUBLIC TO QUESTION OR CROSS 3USTAINABLE $EVELOPMENT STRESS THE INTER EXAMINEPRESENTERS!LLPROCEEDINGSOFTHESE

178 Environmental Sustainability and Hog Production in Manitoba MEETINGSWILLBETRANSCRIBEDANDMADEAVAILABLE SUSTAINABILITY AND THE EFFORTS UNDERWAY IN TO THE PUBLIC THROUGH THE #%# WEBSITE !LL OTHERJURISDICTIONSTOMANAGETHESEISSUES SUBMISSIONS MADE TO THE COMMISSION DURING THEPUBLICSESSIONSWILLALSOBEMADEAVAILABLE THROUGH THE #%# WEBSITE -EMBERS OF THE 0ARTICIPANT!SSISTANCE PUBLIC MAY ALSO SUBMIT WRITTEN RESPONSES 3MALL lNANCIAL AWARDS WILL BE AVAILABLE TO CLARIlCATIONS ORCOMMENTSRELATINGTOISSUES ASSIST LOCAL COMMUNITY AGRICULTURAL AND RAISED AT THE MEETINGS THESE COMMENTS ARE ENVIRONMENTAL GROUPS AND INDIVIDUALS TO REQUIREDBY-AY  PREPARE PRESENTATIONS TO BE MADE TO THESE HEARINGS 4HE DEADLINE FOR APPLICATION FOR 'IVEN THE SCOPE OF THE INVESTIGATION THE THISSUPPORTHASBEENREMOVEDANDREQUESTS #%#ISPARTICULARLYINTERESTEDINHEARINGFROM WILL BE ACCEPTED UNTIL THE CONCLUSION OF THE THEPUBLICONTHEFOLLOWINGISSUES PUBLIC MEETINGS &OR FURTHER INFORMATION ON THESEFUNDSCONSULTTHEWEBSITEORCONTACTTHE s.UTRIENTMANAGEMENT #OMMISSIONDIRECTLY s-ANUREMANAGEMENT 2ESEARCH s,ANDUSEPLANNINGANDAPPROVAL !SAPARTOFTHISINVESTIGATIONTHE#OMMISSION ALSOINTENDSTOENGAGEACADEMICRESEARCHINA s'ROUNDWATERQUALITY NUMBEROFAREAS4HISRESEARCHWILLBEPOSTED ONTHE#OMMISSIONWEBSITEDURINGTHECOURSE s'ROUNDWATERSUPPLY OFTHEINVESTIGATION s3URFACEWATERQUALITY Manitoba Clean Environment Commission 305-155 Carlton St. s3OILQUALITY Winnipeg, MB R3C 3H8 Ph: 204-945-7091 s/DOUR 800-597-3556 (toll free in Manitoba) Fax: 204-945-0090 s$ISEASETRANSMISSION e-mail: [email protected] website: www.cecmanitoba.ca s#LIMATECHANGE s%NVIRONMENTALLIABILITY s4HEAPPROACHTAKENTOTHESEISSUESINOTHER JURISDICTIONS

)N THEIR DISCUSSIONS OF ANY OF THE ABOVE TOPICS MEMBERSOFTHEPUBLICAREENCOURAGED TOADDRESSSUCHISSUESASEXISTINGLEGISLATION AND REGULATIONS TRAINING REQUIREMENTS CURRENT PRACTICE ALTERNATIVES INSPECTION ENFORCEMENT OVERALLIMPACTONENVIRONMENTAL 179 Manitoba Clean Environment Commission $ATESANDLOCATIONSFORTHE-ANITOBA#LEAN %NVIRONMENT#OMMISSION(OG0RODUCTION )NDUSTRY2EVIEW(EARINGS -ARCH  7INNIPEG $ELTA7INNIPEG 3T-ARY!VENUE nPM nPM -ARCH  3TONEWALL 2OYAL#ANADIAN -AIN3TREET nPM ,EGION nPM -ARCH  !RBORG !RBORG"IFROST /N)NGOLFS3TREET nPM #OMMUNITY#ENTRE nPM -ARCH  -ORDEN -ORDEN&RIENDSHIP .ORTH2AILWAY nPM #ENTRE 3TREET nPM -ARCH  +ILLARNEY 2OYAL#ANADIAN &INLAY3TREET nPM ,EGION nPM -ARCH  3T#LAUDE 3T#LAUDE 0ROVINCIAL2OAD nPM 2ECREATION#ENTRE nPM -ARCH  %MERSON %MERSON#OMMUNITY #HURCH3TREET nPM #OMPLEX nPM -ARCH  $AUPHIN 5KRAINIAN#ATHOLIC TH!VENUE(ALL nPM (ALL nPM !PRIL  7HITEMOUTH 7HITEMOUTH (ENDERSON3TREET nPM 2ECREATION#ENTRE nPM !PRIL  &RIEDENSFELD &RIEDENSFELD +M3OUTHOF nPM #OMMUNITY#ENTRE 3TEINBACHON(IGHWAY nPM  !PRIL  &RIEDENSFELD &RIEDENSFELD +M3OUTHOF nPM #OMMUNITY#ENTRE 3TEINBACHON(IGHWAY  !PRIL  6IRDEN %LKS(ALL  RD!VENUE3OUTH nPM nPM !PRIL  (AMIOTA (AMIOTA$ISTRICT -APLE!VENUE%AST nPM 3PORTS#OMPLEX nPM !PRIL  "RANDON +EYSTONE  TH3TREET nPM !GRICULTURAL#ENTRE nPM !PRIL  "RANDON +EYSTONE  TH3TREET nPM !GRICULTURAL#ENTRE !PRIL  0ORTAGELA #ANAD)NN 3ASKATCHEWAN nPM 0RAIRIE !VENUE nPM !PRIL  7INNIPEG 2ADISSON(OTEL 0ORTAGE!VENUE nPM 7INNIPEG$OWNTOWN

180 Appendix 3 Participants in the public portion of the Investigation Presenters to the Public Meetings Presenter Affiliation Location of presentations Adema, Matt Private Portage Arklie, C. Hugh Private Whitemouth Armbruster, Ray Manitoba Cattle Producers Portage Association Bailey, Lorne Deerboine Colony Brandon Barkley, Barbara Private Virden Barnes, David Private Brandon Baron, Alan Private Brandon Bell, Ron Association of Manitoba Portage Municipalities Blackbird, Dwayne Keeseekoowenin Ojibway Brandon Nation Blixhavn, Gerry Private Killarney Blixhavn, Jeff Private Killarney Bruneau, Bob RM of Lac du Bonnet Whitemouth Bryksa, Tracy Manitoba Pork Council Winnipeg Burns, Vicki Winnipeg Humane Society Winnipeg Caners, Alan Private Arborg Cavers, Doug RM of Hanover Friedensfeld Cherepak, Bob Private Arborg Clayton, Liz Private St. Claude Clegg, Carol Private Whitemouth Clubb, Lindy Wolfe Creek Conservation Winnipeg Group Cochrane, Bill Private Arborg Comte, Real Private St. Claude Cousins, Irene Private Virden Dalgarno, Bruce Private Brandon Davy, Robert RM Lorne St. Claude Derenchuk, George Private Winnipeg Desilets, Roger Private Hamiota Dick, Scott Maple Leaf Brandon Dickson, Andrew Manitoba Pork Council Winnipeg Dirks, Cal Private Whitemouth Dolecki, Joe Private Virden English, Clair Private Hamiota Enns, Walter Cargill Ltd. Friedensfeld Ewacha, Curtis Private Winnipeg

181 Manitoba Clean Environment Commission

Presenter Affiliation Location of presentations Fefchak, John Private Virden Ferriss, Bryan Porkchop Enterprises Ltd. Dauphin Francois, Twyla Animals’ Angels Winnipeg Freedy, Joe J and R Livestock Brandon Consultants Frieg, Ab Puratone Friedensfeld Friesen, Karen Tourand Farms Friedensfeld Friesen, Wendy Private Morden Froese, Beverly Public Interest Law Centre Portage Froese, Harold Manitoba Egg Producers Winnipeg Gibson, Janine Organic Food Council of Portage Manitoba Giesbrecht, Daniel Private Brandon Graydon, Cliff Private Emerson Gregory, Eric James Richardson Friedensfeld International Grenier, Adrien Private Friedensfeld Gross, Andy Mayfair Colony Killarney Gross, Irvin Rolling Acres Colony Dauphin Gross, Sam Clearview Colony Portage Gurney, Dean Puratone Virden Harris, Harry Alonsa Conservation Dauphin District Harrison, Bill Private St. Claude Hazzledine, Mick Nutrition Partners Friedensfeld Heaman, Vince Private Virden Hedges, Murray Private Arborg Hedman, Louise Private Winnipeg Hersak, Mickey Private Hamiota Hiebert, Mary Jane Steinbach Chamber of Friedensfeld Commerce Hofer, Ben Rock Lake Colony Stonewall Hofer, Edward James Valley Colony St. Claude Hofer, Edwin Miami Colony Morden Hofer, Jake Deerboine Colony Brandon Hofer, James Starlite Colony Portage Hofer, Larry Marble Ridge Colony Arborg Hofer, Mel Deerboine Colony Brandon Hofer, Phillip James Valley Colony St. Claude Hofer, Robert Wellwood Colony Killarney Hofer, Sam Spring Valley Colony Brandon

182 Environmental Sustainability and Hog Production in Manitoba

Presenter Affiliation Location of presentations Hofer, Tim Willow Creek Colony Killarney Hombach, Peter Deerboine Colony Brandon Hunter, Archie RM of Franklin Emerson Johnson, Byron Private Killarney Johnston, Ron Private Arborg Keating, Lyle Private Hamiota Kentner, Carole Private Killarney King, Dwight RM of Killarney-Turtle Killarney Mountain Kleinsasser, Ed Sunnyside Colony Portage Kleinsasser, Jonathan Crystal Springs Colony Friedensfeld Kleinsasser, Mr. Rock Lake Colony Stonewall Kleinsasser, Raymond Sunnyside Colony Portage Klippenstein, Dan Excel Playgreen Friedensfeld Koroluk, Glen Beyond Factory Farming Portage Kroeker, John Penner Farm Service Friedensfeld Kynoch, Karl Manitoba Pork Council Winnipeg Kynock, David Rolling Acres, Grass River, Dauphin and Riverside Colonies Leschyshyn, Joe Private Arborg Lins, Scott Private Emerson Loewen, Lyle Private Emerson Loveridge, Carol MFL Occupational Health Friedensfeld Centre Ludwick, Diana MFL Occupational Health Friedensfeld Centre Mackie, Craig Private Stonewall Mackling, Al Private Winnipeg Maendel, Cameron Fairholme Colony, St. Claude Maendel, Gerry New Rosedale Colony St. Claude Maendel, Larry, Blue Clay Colony Emerson Maendel, Mike Blue Clay Colony Emerson Maendel, Mike Suncrest Colony Friedensfeld Maendel, Rick Fairholme Colony St. Claude Magwood, Marvin Private Killarney Mah, Peter Manitoba Pork Council Winnipeg Manchur, David Private Dauphin Manness, Peter Private Portage Martens, Herm RM of Morris Morden Marykuca, Peter Private Arborg

183 Manitoba Clean Environment Commission

Presenter Affiliation Location of presentations Massey, Bill Concerned Citizens of Stonewall Grosse Isle Matheson, George Private Stonewall McCowan, Jim Concerned Citizens of Stonewall Grosse Isle McEwan, Les Deerwood Soil and Water Morden Association McFadden, Wanda Manitoba Farm Winnipeg Stewardship Association McKay, Robert McKay GENSTAT Brandon Consultants McLean, Robert Private Morden McNaughton, Jason MaxPro Feeds Arborg Neumann, Sieg RM of Morris Morden Newton, Weldon Private Brandon Nichol, Miriam Private Killarney Nichol, Wayne Private Killarney Nikiforuk, Andrew Springfield Hog Alert Winnipeg Orchard, Gordon Deerwood Soil and Water Morden Association Pauls, Darcy Puratone Arborg Pavelin, George Private Dauphin Penner, Calvin Private Stonewall Penner, Jack MLA Emerson Emerson Penner, Zack Private Virden Peters, Lyle Private Friedensfeld Peters, Rick Steve’s Livestock Transport Friedensfeld Pip, Eva University of Winnipeg Whitemouth Plett, Ray Private Friedensfeld Plett, Ron Private Arborg Poetker, Alf Private St. Claude Poetker, Bill Private Killarney Powell, Larry Private Dauphin Prejet, Normand Private St. Claude Prejet, Rick Private St. Claude Preun, John Manitoba Pork Marketing Stonewall Prychun, Patrick Impact Products Brandon Pryzner, Ruth Private Brandon Ransom, Alan Manitoba Farm Winnipeg Stewardship Association Redekop, Doug Keystone Organic Nutrient Winnipeg Applicators Associaton

184 Environmental Sustainability and Hog Production in Manitoba

Presenter Affiliation Location of presentations Remple, Marg Rempelco Acres Ltd. Friedensfeld Rogasin, Al Private Brandon Rolfe, David Keystone Agricultural Brandon Producers Ross, Ted Roseisle Creek Watershed Portage Association Routledge, Scott Private Hamiota Schinkel, Bob Private Friedensfeld Schnell, Brad Agri-trend St. Claude Senff, Bob Private Virden Sharpe, Martin Private Brandon Shepherd, John Private Virden Shepherd, Kim Private Virden Sheridan, Mike Sheridan Heuser Provis Brandon Swine Health Services Siemens, Kurt Private Emerson Silinski, Shanyn Manitoba Farm Animal Driedensfeld Council Smith, Cheryl Sandpiper Beach/Lake Portage Manitoba Estates Smith, Randy Sandpiper Beach/Lake Portage Manitoba Estates Stahl, Edward Grass River Colony Dauphin Stead, David RM of Morton Killarney Steendam, John Private Whitemouth Storey, Kate Private Dauphin Stott, Sheldon Hytek Friedensfeld Street, Brandy Manitoba Manure Winnipeg Management and Livestock Initiative Swann, Bert Hamiota Economic Hamiota Development Corporation Sweetnam, Miriam Private Morden Tait, Fred HogWatch Manitoba Portage Tannas, Lorne Private Hamiota Tibbets Fefchak, Norma Private Virden Timmerman, Raymond Private St. Claude Toews, Stan Private Friedensfeld Tolton, Garry Private Hamiota Traverse, Henry Jackhead Fisheries Arborg Unrau, Martin Manitoba Cattle Producers Portage Association Vaag, Rick Private Whitemouth

185 Manitoba Clean Environment Commission

Presenter Affiliation Location of presentations Van Aert, John Private Whitemouth Van Slyke, Victor ATD Waste Systems Inc. Winnipeg Vielfaure, Denis Hytek Friedensfeld Vis, Peter Precision Feed and Stonewall Envirotech System Waldner, Johannes Baker Colony Better Air Portage Systems Waldner, Mike Cool Spring Colony Brandon Watson, Herb Private St. Claude Whitaker, John Private Dauphin White, Gordon Private Brandon Wiebe, Art HogWatch Manitoba Brandon Wipf, Joe Broad Valley Colony Arborg Wipf, George Souris River Colony Virden Wishart, Ian Private Portage Wolhgemuth, Victor Private Whitemouth Wruck, Gus, RM of Lac du Bonnet Whitemouth Young, David Whitemouth Soil and Whitemouth Water Association

Presenters of written submissions Presenter Affiliation Barkely, Barbara Private Baumel, Syd Private Bergmann, Rick, Private Brethour, Ed Private Carter, Nick Private Egert, Emil RM of Cornwallis Fefchak, John Private Gefreiter, Margaret Private Harrison, Bill Private Hartle, Katie Private Hedman, David Private Henderson, Chris Southern Chiefs’ Organization Inc. Horbaty, Fred Private The Isenschmids Private Kavalench, Donald Private Kennedy Courcelles, Cheryl Private Keys, Shirley Private King, Catherine Private

186 Environmental Sustainability and Hog Production in Manitoba

Presenter Affiliation Kornelson, Dennis Animal Nutrition Association of Canada Koroluk, Glen Beyond Factory Farming Coalition Kostiniuk Family Private Kowalke, Kaela Private Lennon, Marcel Private Leschyshyn, Joe Private Lowe, Erica Private Mailman, Mariah Private Marykuca, Peter Private Massey, Bill and Dorothy Private McPherson, Dan Brandon and Area Planning District Medro, Dana Private Mercier, Stephanie Private Trevan, Michael Dean Agriculture, University of Manitoba Miller, Kevin Private Newton, Scott Private Nichol, Jim and Colleen Private Novek, Joel Private Olfert, Milt Private Organic Plant Worker Co-op Picardie Farms Piniuta, Marilyn Private Powell, Larry Private Public Interest Law Centre, Rosolowski, Henry Private Saxton, Stan Private Stozek, Troy Private Suggett, Glen Private Tetrault, Ray Private Trafford, Denise Private Vanbenlan, Lance Private Waldner, Mike Cool Springs Colony Wiebe, Dave Private

187 Manitoba Clean Environment Commission

188