TREPA on fur farm management

TREPA supports the regulation of the fur farm industry as it relates to the issue of management of waste and runoff into our water systems. The following considerations have been shared with our Ministers of Agriculture and Environment, both of whom have a responsibility in this area.

Process:

  1. Public involvement is needed from all concerned stakeholders in developing these regulations. We would like to see a first draft of the regulations, once they are ready, either e-mailed out or put on  the Department of Agriculture website, and a reasonable period of time given for stakeholders to comment.  We suggest giving stakeholders one month to review the draft and comment, prior to redrafting.
  2. These regulations should be done right, before they are circulated.  If this cannot be done before the June deadline, then the deadline should be pushed further ahead.
  3. The bigger the technical drafting committee, the more unwieldly.  That said, a limnologist from Department of Environment should be an explicit participant.  Darrel Taylor may fill the bill, since he knows the area.

Content:

  1. The new regulations should use what has already been developed  in the Environmental Regulations Handbook for Nova Scotia Agriculture, and  Manure Management Guidelines, as well as regulations.
  2. It is encouraging to hear that Farm Management Plans, developed in consultation with accredited expertise, will now become mandatory, and that they will be more comprehensive than the current voluntary Environmental Farm Plans and Nutrient Management Plans.  Care should be taken to assure that no loopholes slip in, in the process of incorporating details of the voluntary plans into the mandatory management plans.
  3. Any significant changes to the farm (for example, significant expansion, significant increase in number of animals) would need a new approval.  “Significant” requires clear definition , and needs to take  into account incremental “non-significant” changes.
  4. It’s good that inspectors will have the authority to make unannounced visits, but who enforces and the minimum frequency of visits needs to be specified.
  5. Inspection results should be publicly available.  Data should be available on the basis of watershed area, since this, not municipality, is the environmentally relevant unit .
  6. Enforcement budget is a concern.  So far, violators can get away with it, even when reported.  Money is tight, but this needs to be addressed. Penalties need definition and should be sufficient to discourage violations strongly.
  7. Environmental and water quality protection, disease control, and nutrient management all need to be covered by the regulations.

External to the regulations, but of major importance:

  1. The fact that an approval may be granted irrespective of past history or neighbouring land use is a major concern, and somehow needs to be addressed by the province. Cumulative effects of past land use, and management on the basis of watershed area need to guide the regulatory process.  Otherwise, problems with pollution will continue to affect the environment, citizens and governments.
  2. The by-laws of various municipalities and provincial regulations need better coordination. Better communications among the Departments of Agriculture, Environment, Natural Resources, and municipalities would be helpful.  Because of the division of authority among departments, there is nobody to take control of the situation.
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