RESOLUTION 1-19: LOSS OF 2% LIQUID STRYCHNINE
THEREFORE BE IT RESOLVED THAT ALBERTA’S AGRICULTURAL SERVICE BOARDS REQUEST Health Canada and the Pest Management Regulatory Agency reconsider their decision and leave 2% Liquid Strychnine on the market available on a permanent basis to agricultural producers to utilize on their farms for control of Richardson’s Ground Squirrels.
Health Canada: Pest Management Regulatory Agency
Thank you for your correspondence of February 11th, 2019, addressed to the Honourable Ginette Pettipas Taylor, Minister of Health, regarding the proposed re-evaluation decision to cancel the use of strychnine for the control of ground squirrels. The Minister has asked that I respond on her behalf.
In Canada, pesticides are regulated federally under the Pest Control Products Act, which is administered by Health Canada’s Pest Management Regulatory Agency (PMRA). Our number one priority is to protect the health and safety of Canadians and their environment, including non-target wildlife.
Before a pesticide is allowed to be used or sold in Canada, it must undergo a rigorous scientific assessment process to determine that the health and environmental risks of using the product are acceptable, when used according to label directions. In addition, Health Canada periodically re-evaluates pesticides that are on the market to assess whether they continue to meet the Department’s health and environmental standards and hence whether they should continue to be permitted for use in Canada. Health Canada will take regulatory action at any time should unacceptable risks to human health or the environment be identified.
As you are aware, Health Canada published a proposed re-evaluation decision, PRVD2018-13: Strychnine and Its Associated End-use Products (Ground Squirrel Use), in June 2018. This document proposed to cancel the use of strychnine for ground squirrel control due to risks of concern for non-target organisms, including species at risk. As indicated in this document, multiple lines of evidence (risk assessment based on available information, incident reports, information from provinces including information generated through the Integrated Pest Management Committee) indicated that risks of concern for non-target poisonings continue to occur with the use of strychnine. Reliance on strychnine may not be sustainable in the long-term due to the lack of practical mitigation measures to protect non-target organisms.
During the consultation period, several comments relating to the proposed decision were received from the Canadian public and stakeholders, including Agricultural Service Boards, and are currently under review.
Once Health Canada has considered all of the comments and information received from stakeholders and members of the public, a science based approach will be applied in making a final decision.
Please note that there are alternatives to strychnine as mentioned in the consultation document:
- chlorophacinone and diphacinone (multi-feed anticoagulant baits);
- zinc phosphide (non-anticoagulant bait);
- aluminum phosphide (fumigant); and
- white mustard seed powder and sodium alpha-olefin sulfonate (foam).
Should you have further questions regarding pesticides and the federal pesticide regulatory system, please contact the PMRA by telephone at 1-800-267-6315 or by email at email@example.com.
Agriculture and Agri-Food Canada
On behalf of the Honourable Marie-Claude Bibeau, Minister of Agriculture and Agri-Food, I wish to acknowledge receipt of your correspondence to her predecessor, the Honourable Lawrence MacAulay, and the enclosed copy of the Agricultural Service Board’s “Resolution 1-19: Loss of 2% Liquid Strychnine”.
As you may know, the Pest Management Regulatory Agency (PMRA) has completed a consultation on strychnine and associated end use products in order to make a decision on its future use. I have taken the liberty of forwarding a copy of your correspondence to the Office of the Honourable Ginette Pettipas Taylor, as this matter falls under her jurisdiction. I am certain that Minister Pettipas Taylor will give your concerns every consideration.
RESOLUTION 2-19: WILDLIFE PREDATOR COMPENSATION PROGRAM ENHANCEMENT
THEREFORE BE IT RESOLVED THAT ALBERTA’S AGRICULTURAL SERVICE BOARDS REQUEST that the Ministers of Environment and Parks, Justice and Solicitor General, and all other relevant government ministries implement an enhanced Predator Compensation Program that could utilize the GPS location and date time features and photo capabilities of smart phone technology to provide photographic or video evidence to assist in the confirmation of livestock death and livestock injury in a timely and prompt manner, and reduce the number of physical site investigations Fish and Wildlife Officers must conduct.
Alberta Agriculture and Forestry
Through the Agriculture Financial Services Corporation (AFSC), Alberta Agriculture and
Forestry (AF) is responsible only for Wildlife Damage Compensation Program and not for the Wildlife Predator Compensation Program; therefore, neither AFSC nor AF is in a position to provide response to Resolution 2-19.
The Wildlife Predator Compensation Program is administered by the Alberta Environment and Parks (AEPs) Fish and Wildlife section, and we will defer to them for response.
Alberta Environment and Parks
The Wildlife Predator Compensation Program accepts electronic photos from producers as supplementary evidence in determining eligibility of compensation claims. Such photos are particularly valuable in cases where key evidence may be lost if not immediately recorded (weather, scavenging, etc.). The protocol for this program is to initiate investigations within 24 hours of notification of a livestock loss due to predation. Only on rare occasions do response times exceed this protocol, and measures are taken to ensure such delayed responses do not affect decisions about compensation.
Environment and Parks staff evaluate the field investigative response times for the Wildlife Predator Compensation Program on an annual basis, and adjust the program by stationing seasonal problem wildlife technicians in municipalities with the highest incidence of predation. To continue to support producers, in 2018, department staff enhanced the “Ranchers Guide to Predator Attacks” and included additional tools to focus producers on collecting the types of evidence most useful to investigators. Municipalities can order copies of this publication from the department Information Centre by contacting firstname.lastname@example.org.
The department is reviewing several initiatives to reduce livestock losses to predators, including evaluation of proposed program timelines, costs and potential opportunities for stakeholder partnerships.
Mark Heckbert, Provincial Wildlife Conflict Specialist, would be pleased to meet with the ASB Provincial Committee to further discuss any issues regarding the Wildlife Predator Compensation Program. You can reach Mark Heckbert at email@example.com or at 780-523-6517 (dial 310-0000 for a toll-free connection to any Government of Alberta number).
Alberta Justice and Solicitor General
Thank you for your inquiry below with respect to an outstanding response to the Provincial Agricultural Service Board Committee’s resolution: 2-19: Wildlife Predator Compensation Program Enhancement.
Upon review of resolution 2-19, it was determined that Alberta Environment and Parks (AEP) was the more appropriate ministry to respond, given the Wildlife Predator Compensation Program falls under the jurisdiction of that ministry. I am pleased to advise that the ministry of Alberta Justice and Solicitor General did provide AEP with input into their response, prior to the spring provincial election held on Tuesday, April 16, 2019.
For further updates, please feel free to contact the Deputy Minister’s Office of Alberta Environment and Parks.
RESOLUTION 3-19: DEADSTOCK REMOVAL
THEREFORE BE IT RESOLVED THAT ALBERTA’S AGRICULTURAL SERVICE BOARDS REQUEST that the Provincial Government compensate producers fifty percent (50%) of the deadstock pick up fees with producers bearing the remainder of costs.
Alberta Agriculture and Forestry
The Disposal of Dead Animals Regulation (Alberta) provides for several methods of disposal that are acceptable for routine on-farm animal deaths (provided the animal was not infected with a provincially or federally reportable disease and the animal was not euthanized with drugs): by landfill, burial, burning, composting, rendering, and natural disposal. Certain additional conditions are outlined in the regulation that are dependent on the type of disposal method chosen.
While the presence of Bovine Spongiform Encephalopathy (BSE) in Canada did change the availability of rendering in some locations of the province, this was largely due to a change in the demand for the services in more remote areas, and a subsequent decision by renderers to change the supply of their services. AF has reviewed options to subsidize rendering costs in order to increase the number of samples available for BSE surveillance; the results of this analysis has continued to suggest a lack of return on investment, with a significant increase in cost and very little increase in the number of samples.
The most valuable samples for BSE surveillance are those collected on-farm, rather than those collected at deadstock/rendering facilities, because of the presence of a disease history for those collected on farm. The BSE surveillance program currently pays producers $75 per animal to assist with keeping the carcass from predation while testing is performed.
As part of emergency preparedness for foreign animal disease incursions, ail farms should consider developing an on-farm disposal program that will work in all seasons. Municipalities could be eligible for funding under the Canadian Agricultural Partnership program for the development of emergency preparedness plans, including option for locating sites to dispose of deadstock. More information is available at: https://cap.alberta.ca/CAP/.
RESOLUTION 4-19: CARBON CREDITS FOR PERMANENT PASTURE AND FORESTED LANDS
THEREFORE BE IT RESOLVED THAT ALBERTA’S AGRICULTURAL SERVICE BOARDS REQUEST that Alberta Agriculture and Forestry develop a process to allow farmers and landowners to access carbon credits for land used for permanent pasture, perennial forage crops or land that is left forested.
Alberta Agriculture and Forestry
AF recognizes that carbon sequestration will be an important source of emissions reductions, and we support market-based approaches to emissions reductions that compensate producers for doing their part to combat climate change.
Under the Climate Change and Emissions Management Act and the associated regulations, Alberta policy is for measurement and mitigation of ail greenhouse gases (GHGs). The regulations specify 23 different gases, three of which are common in the agriculture sector: carbon dioxide, nitrous oxide, and methane.
The development of offset protocols requires careful consideration to ensure they are
science-based, verifiable, and robust. Protocols must consider all relevant or affected GHG emissions. Changes in nitrous oxide and methane must also be taken into account, as well as carbon/carbon dioxide. Additional considerations include:
- Establishing science-based baselines;
- Determination of clear, well-defined geographical boundaries;
- Establishing a framework;
- Identifying monitoring, verification, and reporting requirements;
- Ensuring permanence and avoiding leakage;
- Ensuring proper valuation of credits (quantification of the impact of an action and proper economic valuation);
- Establishing legal and institutional frameworks; and
- Organizing stakeholders and obtaining ‘buy-in*.
Offsets are measured by the difference in emissions when a producer changes their practices or implements a technology (not in a business-as-usual state); that is, it is not about total carbon in the soil, but how soil carbon is altered with a change in management. Offsets in perennial agriculture crops, for example, include a livestock component. Management changes to produce more forages may promote more cattle (fed on or off the field) releasing more methane and nitrous oxide. The positive change in carbon may, thus, be reduced by the increased production of these other two gases.
AF is currently working with the Alberta Climate Change Office to develop a carbon
sequestration protocol for forestry in collaboration with stakeholders. The Government of Alberta may consider developing additional protocols, including permanent pasture or perennial forage crops, as science and policy evolves to make them a market opportunity.
Alberta Environment and Parks
Environment and Parks administers the Alberta Emission Offset System, and Agriculture and Forestry often provides valuable input into the protocol development process. Currently, the Carbon Competitiveness Incentive Regulation (CCIR) enables the Alberta Emission Offset System. A government-approved quantification protocol is required for activities to generate emission offsets. There are currently no approved protocols for the activities list by ASB (permanent pasture, perennial crops and land left forested).
Organizations interested in developing a protocol for a reduction or sequestration activity may submit a request to develop a protocol to Environment and Parks. Information on the process and the template for submitting a request is available in the “Technical Guidance for Offset Protocol Development and Revision” (July 2018), which you can find by searching for the document’s title at https://open.alberta.ca/publications.
Environment and Parks evaluates requests and selects protocols to be developed or revised. Factors considered in the selection process include available resources, magnitude of potential reductions, ability to accurately quantify reductions or sequestration, additionality and alignment with policy priorities. The deadline to submit a request is the end of calendar year. If a protocol is not selected, the protocol developer is welcome to submit another request the following year.
Biological sequestration protocols are challenging because the science is still evolving for measurement, monitoring and quantification of land and trees as both sources and sinks for atmospheric carbon dioxide. It is also challenging to quantify incremental reduction or sequestration due to implementing a management practice or technology. There must be an increase in the rate of sequestration compared with the baseline scenario, and the increase must be measured and quantified in a way the meets the rigour of Alberta’s regulatory system.
RESOLUTION 5-19: MULTI-STAKEHOLDER COMMITTEE TO WORK AT REDUCING THE USE OF FRESH WATER BY THE OIL AND GAS INDUSTRY IN ALBERTA
THEREFORE BE IT RESOLVED THAT ALBERTA’S AGRICULTURAL SERVICE BOARDS REQUEST that the Provincial Agricultural Service Board Committee request the Government of Alberta to immediately strike a multi-stakeholder committee to work at reducing the use of fresh water by the oil and gas industry in Alberta.
Alberta Agriculture and Forestry
AEP, Alberta Energy, and the Alberta Energy Regulator are leading the efforts to minimize the use of fresh water in oil and gas extraction activities. As this resolution has been fonwarded to AEP, as well, AF will defer to that department for response.
Alberta Environment and Parks
Water use, including where, when and how much water can be withdrawn, is regulated under the Water Act. Diversion licences are granted to applicants when sufficient water is available to meet both ecosystem requirements and the rights of existing licence holders. The Alberta Energy Regulator (AER) is responsible for issuing water licences on behalf of the government for energy development activities.
The 2006 Water Conservation and Allocation Policy for Oilfield Injection requires operators to assess alternatives to freshwater prior to applying for a water licence for enhanced oil recovery (water floods) and in-situ operations. This policy made significant improvements to water productivity.
In February 2018, Environment and Parks issued the Directive for Water Licensing of Hydraulic Fracturing Projects – Area of Use Approach (the directive). The directive provides direction to the AER to ensure a consistent approach to water licensing of hydraulic fracturing projects with multi-year operations. The directive requires operators to demonstrate their need for water and to conduct an assessment of alternatives to fresh water. You can find the directive by visiting https://open.alberta.ca/publications and searching for “directive for water licensing of hydraulic fracturing.”
Because these issues are wide-ranging and complex, I welcome the opportunity to meet with you, along with some of my staff, to discuss these important topics.
The resolution falls under the jurisdiction of Environment and Parks. I believe they will be reaching out to you shortly.
RESOLUTION 6-19: STEP PROGRAM AGRICULTURAL ELIGIBILITY
THEREFORE BE IT RESOLVED THAT ALBERTA’S AGRICULTURAL SERVICE BOARDS REQUEST that Government of Alberta review its Summer Temporary Employment Program to include farms and small businesses that are not incorporated.
Alberta Culture and Tourism
Our office had forwarded your previous email to the Ministry of Labour to reply on our behalf our Ministry as this resolution would fall under their mandate. I have attached a copy of the response that was sent out on March 22, 2019.
I appreciate that the Provincial Agricultural Service Board Committee recognizes the importance of the Summer Temporary Employment Program (STEP). STEP provides students with the opportunity to build meaningful work experience, increase their skills and workplace knowledge and help prepare them for the future.
Currently, to be eligible to participate in STEP, businesses must be incorporated or registered under provincial or federal legislation. Small businesses within the province must be registered in Alberta, have been operating for no less than one year (from the date of application) and have an Alberta Corporate Access Number (ACAN), which is used for verification and validation purposes. Employers that do not meet the eligibility criteria cannot be funded through STEP, regardless of their industry.
When providing funding to employers to hire students, it is important that all organizations are verified to ensure they meet all program requirements. Application assessment includes verifying the position is in Alberta, verifying the business is registered in Alberta (as noted above) and is in good standing with Alberta’s health and safety legislation, and confirming that all other eligibility criteria is met.
Please be assured Labour is committed to monitoring our programs to support workers and employers, including STEP, and your organization’s feedback will be taken into consideration.
Agriculture and Forestry also provides programs and services that may assist farm operators, including the Summer Farm Employment Program, which provides opportunities for full-time farm work experience for young people. Employers are encouraged to call the Agriculture and Forestry contact centre at 310-FARM or visit their website at www1.agric.gov.ab.ca/general/progserv.nsf/all/pgmsrv35 to learn more about this and other programs that are available for the current year.
Employers considering applying for the Canada Summer Jobs Program, available through the Government of Canada, can find more information atwww.canada.ca/en/employment-social-development/services/funding/canada-summer-jobs.html or call 1-800-935-5555.
If you have comments about the Canada Summer Jobs Program you may wish to contact the Honourable Patricia Hajdu, Minister of Employment, Workforce Development and Labour, at:
Honourable Patricia A. Hajdu
Minister of Employment, Workforce Development and Labour
House of Commons
Ottawa, ON K1A 0A6
EMERGENT RESOLUTION E1-19: ACCESS TO AGRICULTURE SPECIFIC MENTAL HEALTH RESOURCES
THEREFORE BE IT RESOLVED THAT ALBERTA’S AGRICULTURAL SERVICE BOARDS REQUEST that the Provincial Government of Alberta facilitates the formation of a free, year-round, all hours, mental health crisis hotline, dedicated to the agriculture industry, providing farmers with direct access to uniquely qualified professionals and resources, whom have both an understanding of mental health issues and agriculture specific stresses.
FURTHER THEREFORE BE IT RESOLVED THAT ALBERTA’S AGRICULTURAL SERVICE BOARDS REQUEST that the Provincial Government of Alberta secure long-term, sustainable funding for the operation and maintenance of this mental health crisis hotline.
Alberta Agriculture and Forestry
AF appreciates Alberta’s Agricultural Service Boards interest in this important topic. Indeed, a 2016 study from the University of Guelph found that 45 per cent of farmers had high stress, while 40 per cent said they would feel uneasy asking for professional help. Thirty-five per cent of Canadian producers could be classified as depressed and 58 per cent of producers meet the criteria for anxiety (https://news.uoguelph.ca/2016/06/farmers-need-want-mental-health-heipsurvev/).
While this study does not offer any Alberta-specific data, Farm Management Canada recently released an “Expression of Interest” to industry stakeholders interested in contributing to an industry-wide, national study on the connection between mental health and farm business management (https://fmc-gac.com/announcements cpt/rei-mh-fbm/). Alberta’s Agricultural Service Boards may consider responding to this call as a means of providing an Alberta perspective, and to further validate the need for the proposed service.
At this time, there is no funding available for a mental health crisis hotline dedicated to
agriculture. AF is committed to reaching out to Alberta Health in the coming months to discuss potential options and strategies to address the concerns of mental health as they specifically relate to the agriculture industry in Alberta.
I appreciate the comprehensive information the Provincial Agricultural Service Board (ASB) Committee provided in the Resolution E1-19: Access to Agriculture Specific Mental Health Resources, and am pleased that the findings are aligned with the approach we are taking to support Albertans who live in rural communities. I understand that agriculture is a stressful occupation with unique mental health concerns.
I assure you that improving mental health supports for farming families in rural communities is a priority for our government. There are a number of activities underway that focus on rural communities.
- Currently, the 211 database (mentioned in your resolution), covers about 65 per cent of the province. It is being expanded to cover the whole province so people can get information about addiction and mental health services that are close to home, especially in rural areas.
- Alberta Health Services is increasing mental health service delivery to rural and remote communities through telehealth services. Telehealth is also used for specialized service delivery in rural areas (e.g., child psychiatry, psychogeriatrics, opioid services) in combination with local Alberta Mental Health staff.
- Alberta Health provided grant funding to, and is working closely with, the Canadian Mental Health Association to improve community-led mental health supports in rural areas. Over the next three years, 150 rural communities (including towns, villages and Indigenous communities) will develop and implement local action plans to improve addiction and mental health services. We are looking forward to seeing the results.
- There have been 40 free Mental Health First Aid (MHFA) for Seniors training sessions offered across Alberta, including rural areas, with more to come. MHFA is an evidence-based course that supports participants to respond to emerging and crisis mental health issues in the people they serve, their co-workers, friends and families.
- It has been recognized as an effective tool for farming communities, and training is also being offered through Farm Credit Canada.
- We are also piloting and evaluating e-counselling options and expanding the Mental Health Capacity Building in Schools program to 18 more schools, including in rural and remote areas of the province, bringing supports to 100,000 children across the province.
Additionally, the Mental Health Help Line provides a province-wide, 24/7 telephone service. This is a confidential, anonymous service that offers help for mental health concerns, including crisis intervention, information about mental health programs and services, and referrals to other agencies, if needed.
There are also agriculture specific health supports available to farming families in Alberta:
- 4-H Farm Management Canada has just launched their Healthy Living initiative, a two-year program available to all 4-H Clubs in Canada. The first year of the program will focus on providing mental health supports to children and youth in collaboration with partners such as the Kids Help Phone. Information is available on their website at https://4-h-canada.ca.
- Farm Credit Canada has a program, Rooted in Strength, that focuses on breaking the stigma of mental health support in the farming community and providing resources to farming families. Information about this program is available on their website at fcc-fac.ca/en/ag-knowledge/wellness.html.
- Do More Ag is a not-for-profit organization focusing on mental health in agriculture, that offers resource listings and works with partner organizations across Canada. Information about this organization is available on their website at domore.org.
I commend you for your advocacy on this matter and appreciate the time you have taken to bring this concern to my attention. The information you have provided will help to ensure that our health care system remains responsive to the needs of all Albertans.
EMERGENT RESOLUTION E2-19: NO ROYALTIES ON FARM SAVED SEED
THEREFORE BE IT RESOLVED THAT ALBERTA’S AGRICULTURAL SERVICE BOARDS REQUEST that Agriculture and Agri-Food Canada and the Canadian Food Inspection Agency abandon the proposal to implement the adoption of End Point Royalties (EPRs) for farm saved seed “trailing royalty contracts”.
Canada Food Inspection Agency
Thank you for sharing your letter of February 11, 2019, which includes the seed royalty resolution (Resolution E2-19: No Royalties on Farm Saved Seed), passed by the Agricultural Service Board. I appreciate you taking the time to write to me about this important matter.
As you may be aware, Agriculture and Agri-Food Canada and the Canadian Food Inspection Agency were asked by the Grains Value Chain Roundtable, a consultative body with broad representation from across the value chain, to launch public consultations on two proposed seed royalty models. The purpose of these proposed “value-creation” models are to stimulate greater investment and innovation in Canada’s cereal sector. The first phase of the consultative process was launched in late 2018 and is an initial step in what government views as a multi-stage discussion process.
The Government of Canada understands that many farmers place considerable value on their ability to save seed and often choose specific crop kinds and varieties that allow for replanting of saved seed in subsequent years. At the same time, a large number of agriculture sector stakeholders have signaled a desire for Canada to consider some form of value-creation model that would allow increased investment in wheat variety development by both public and private breeders across the country. Many producers see increased investment in research and breeding as key to ensuring the long term profitability and competitiveness of Canada’s cereals sector.
The government remains open to hearing all perspectives on this matter, and will consider the feedback heard to inform next steps in the consultative process.