Report of the Commissioner of Environment and Sustainable Development on the Hog Industry in Canada

 

(The full report from the Office of the Auditor General of Canada can be read by clicking here.  What is  presented here is the section dealing with the Hog Industry)

Impacts of hog farming
8.41 Hog farming is an important agricultural activity in Canada. In 2004, Canadian farmers received $4.3 billion from the sale of hogs, according to Statistics Canada. This represents about 12 percent of total farm sales in Canada for that year. Agriculture and Agri-Food Canada reports that in 2004, Canada was the fifth largest producer and the third largest exporter of pork in the world. Canada exports over half the pork it produces, mainly to the United States and Japan, according to Statistics Canada.

Increased growth in the hog industry

In 1995, the federal government eliminated the Crow Rate, a transportation subsidy that helped farmers transport their grain to the nearest port. This forced many farmers in the prairie provinces to look for new ways to use their grain; many now use it as feed for hogs. This is one of the factors that has led to the growth of the hog industry in recent years.

8.42 Based on hog inventories prepared by Statistics Canada in 2005, the hog industry has expanded by almost 50 percent since 1981. The production of hogs is shifting from "farm to factory"—there has been a reduction in farms producing hogs and an increase in hogs on farms (Exhibit 8.6). In 1991, the average hog farm had 345 animals; in 2001, the number had increased to around 900. Some hog farms in Canada have reported as many as 10,000 hogs.

8.43 Quebec, Ontario, and Manitoba lead Canada in hog production. In 2001, over half of all hogs in Canada were produced in Quebec and Ontario. Between 1991 and 2001, the number of hogs produced in Manitoba increased by 97 percent (Exhibit 8.7).

8.44 According to Agriculture and Agri-Food Canada, a hog produces an average of about one tonne of manure per year. Hog manure contains nutrients that are valuable for crop production and that enhance soil properties when properly applied. However, some hog farms do not have enough land on which to spread the manure produced by their hogs or are located away from areas where field crops are produced. If manure is not properly stored or disposed of, it can contaminate the water, soil, and air. Potential impacts include the following:

Contamination of water bodies by bacteria, such as E. coli, giardia, and others, can make water unfit for human use.
Excess nutrients, including nitrogen and phosphorus in water bodies, can result in algae growth, eutrophication, and fish kills.
High concentrations of nutrients and heavy metals building up in the soils can be toxic to crops.
Odours can result from manure storage facilities and field application.
As the concentration of intensive hog operations increases, so does the potential for negative impacts to human health and the environment.

8.45 Canadian scientists are still unsure of the effects that manure from hog farms has on water quality and human health. In May 2002, Quebec responded to the growth of the hog farming industry and citizens' concerns by putting in place a moratorium on the expansion of existing hog farms and on the development of new hog farm operations. Research is currently under way at Lake Huron and Lake Winnipeg to find out whether the eutrophication and bacterial contamination observed are related to the proximity of intensive agricultural activities.

8.46 Governing hog farms is a shared responsibility. Both federal and provincial governments have regulations and initiatives that deal with agricultural activities and the environment. Federal efforts by Agriculture and Agri-Food Canada and Environment Canada focus on research and development to reduce the environmental impacts from agriculture in general, and on compliance with and enforcement of the pollution prevention provisions of the Fisheries Act. Provincial involvement includes, but is not limited to, issuing permits, licensing, enforcing laws and regulations on hog operations, specifying separation distances to wells, and placing restrictions on manure spreading. Local governments regulate building permits and zoning provisions.

8.47 Since 2002, the Commissioner of the Environment and Sustainable Development has received three environmental petitions from Canadians concerned about the potential impacts of hog farming on the environment and on their communities (petitions 37, 39, and 46). Based on statements made in petition responses 37 and 46, we audited Environment Canada and Agriculture and Agri-Food Canada's actions to reduce the impacts of hog farming on the environment.

Environment Canada cannot yet demonstrate that its compliance promotion and enforcement efforts at hog farms are effective

8.48 The Fisheries Act prohibits the direct or indirect deposit of deleterious substances into water frequented by fish. It is the primary federal statutory instrument for enforcement activities related to hog farming. Environment Canada administers and enforces the pollution prevention provisions of the Fisheries Act. For the last three years, Environment Canada has identified the enforcement of these provisions as a priority. In its 1999 Business Case, Environment Canada noted that agriculture posed a risk to the environment and established it as a priority for enforcement under the Fisheries Act. The Department further stated that enforcement activities for this sector would focus on large feed lots. (See photograph)

8.49 Given the growth of the industry, the potential for environmental impacts, Environment Canada's enforcement priorities regarding the Fisheries Act, and the Minister's responses to petitions 37 and 46, we looked at Environment Canada's enforcement activities at hog farms. Our audit determined that it is typically the provinces that receive and deal with complaints about hog farming. Alberta, Ontario, and Saskatchewan have agreements with the federal government to co-operatively administer the pollution prevention provisions of the Fisheries Act. Provinces can also use their own environmental legislation to enforce activities at hog farms. For example, the Province of Ontario received 62 complaints related to hog farming from April 2004 to February 2005, for such issues as manure spills, nuisance odours, and improper spreading practices. The Province convicted three hog farmers for discharging manure into the environment.

8.50 Environment Canada's enforcement activities at hog farms are mostly reactive. The Department initiates investigations of Fisheries Act violations only if it has received a complaint. According to Environment Canada's enforcement database, out of the approximate 7,600 Fisheries Act complaints the Department received from across the country between 2000 and 2004, about 37 complaints involved hog farming. Department officials told us that all complaints were investigated, and Environment Canada had prosecuted one hog farm for violating the Fisheries Act.

8.51 Compliance promotion is a priority for Environment Canada. Although Environment Canada's role in enforcement for hog farms is limited, the Department plays an important role in promoting compliance with the pollution prevention provisions of the Fisheries Act. In 2003, Environment Canada created a new Compliance Assurance Branch. The goals of the branch are to improve the planning of compliance promotion and enforcement efforts and the effectiveness of analysis and reporting of compliance activities. This branch is tasked with determining priorities and fostering links between enforcement and compliance promotion. The Department promotes compliance by preparing and distributing guidelines and policies, consulting with industry associations and working groups, and preparing and presenting educational and training materials.

8.52 In its 2002 response to petition 37, Environment Canada stated that it will likely work on further compliance promotion and enforcement in the Lake Huron watershed, due to the large concentration of intensive livestock operations. It further committed to gathering data on watersheds with the greatest agricultural impacts. In our view, this will help the Department better direct some of its resources toward issues of highest priority.

8.53 The Department met its commitment in the context of the Ontario region. It has undertaken further compliance promotion and enforcement activities in the Lake Huron area. However, we found that the Department does not gather data on a national basis in order to direct resources toward issues of highest priority.

8.54 Environment Canada's compliance promotion activities yield mixed results. Environment Canada informed us that compliance promotion can be more efficient than enforcement. However, the Department has seen mixed results in its efforts to increase farmers' compliance with the pollution prevention provisions of the Fisheries Act. In 2004, the Ontario region of the Department conducted a study at a watershed and found that its compliance promotion activities did not result in any significant new action or improved practices by farmers.

8.55 Environment Canada is working to evaluate and improve the effectiveness of its compliance promotion activities. The Department is developing indicators that will help determine if its actions are having an impact. For example, a pilot study on cattle access to water, conducted in a watershed in the Ontario region, indicated that compliance promotion and enforcement activities increased compliance by 20 percent in the study area. In addition, the Department is in the preliminary stages of developing a database to track and monitor its compliance promotion activities, as it currently does for its enforcement activities. However, the Department could not provide a timeline for when the database or the indicators will be in place.

8.56 Environment Canada does not track what it spends to enforce the pollution prevention provisions of the Fisheries Act . In 1998, the House of Commons Standing Committee on Environment and Sustainable Development recommended that Environment Canada keep comprehensive records on enforcement budgets and expenditures. The Department agreed to do so and has listed enforcement of Fisheries Act provisions as a priority for the last three years. We were therefore surprised to learn that the Department does not code its enforcement activities by Act or regulation and was not able to tell us how much it spends to enforce the pollution prevention provisions of the Fisheries Act. As of 2005, the Department had received $46 million in new funding to improve its compliance and enforcement program for legislation for which it is responsible, including the Fisheries Act. In our view, monitoring results and tracking what it spends to enforce the pollution prevention provisions would enable the Department to better direct its resources.

8.57 Environment Canada does not have a complete picture of who it regulates. Environment Canada is in the third year of a 10-year plan to collect information on those who should be regulated under the pollution prevention provisions of the Fisheries Act and the Canadian Environmental Protection Act, 1999. At this stage, the Department does not yet have all the information required to ensure that its enforcement and compliance promotion activities are being directed toward those who are at greatest risk of breaking the environmental laws that it is mandated to enforce.

8.58 Recommendation. In order to ensure that its compliance promotion and enforcement efforts related to hog farming are effective, Environment Canada should

identify the regulated community,
gather data on a national basis to direct or prioritize resources,
monitor the impacts of its efforts, and
keep comprehensive records on budgets and expenditures.


Environment Canada's response.

Environment Canada agrees with the recommendation. It should be noted, however, that these recommended activities, although directed to hog farming, are relevant to all environmental issues where the Department has compliance promotion and enforcement responsibilities. The Department uses priority-setting mechanisms for both compliance promotion and enforcement activities under the Fisheries Act and the Canadian Environmental Protection Act, 1999. These mechanisms allow for the consideration and prioritization of all issues, including hog farming.

Identification of all hog farms in Canada will be done in fiscal year 2006-07, in collaboration with Agriculture and Agri-Food Canada and provinces. This will help Environment Canada identify watersheds with the greatest agricultural impacts across Canada, and compliance promotion and enforcement efforts regarding hog farming issues will be more easily directed to issues of highest priority. This priority-setting exercise would need to consider the ongoing efforts by provinces and others to reduce the environmental impacts of hog farming operations. For example, many provinces have recently developed nutrient management regulations, which are also supported by various voluntary measures under the Agricultural Policy Framework.

To improve monitoring of the impacts of its efforts, Environment Canada will continue to track its compliance promotion and enforcement activities. The Department will also continue to pilot a database that could be used nationally.

Agriculture and Agri-Food Canada's strategic approach to reducing the environmental impacts of hog farming is not clear

8.59 In 1998, the hog industry asked Agriculture and Agri-Food Canada to re-examine its role and work with industry and the provinces to develop a more comprehensive and co-ordinated approach to the environmental issues faced by the hog industry. The Department and the hog industry conducted a review of the environmental challenges and together recommended that a strategic approach was needed to determine priorities in research, technology development, and dissemination.

8.60 Also in 1998, Agriculture and Agri-Food Canada announced it would spend $2 million to develop a hog environmental management strategy. The purpose of the strategy was to develop a national approach to finding effective and affordable solutions to the environmental challenges of the hog industry by 2001. During our audit, the Department informed us that its efforts focussed on research, technology development, and communications, but that a hog environmental management strategy had not been developed.

8.61 In our 2001 Report (see Chapter 1—A Legacy Worth Protecting: Charting a Sustainable Course in the Great Lakes and St. Lawrence River Basin), we observed that a strategic approach to deal with the environmental impacts of hog farming was more important than ever. Our audit concluded that it was not clear if the initiatives of Agriculture and Agri-Food Canada would produce the strategic, well-co-ordinated effort that was needed to assist farmers.

8.62 In 2001, the Agricultural Policy Framework moved the Department from a sector-based approach to an issue-based approach. The environmental component of the framework focusses on reaching goals in the areas of air, water, soil, and biodiversity. Programs dealing with the environmental impacts of hog farming, including those developed under the framework, are listed in Hog farming programs and initiatives. Department officials told us that the responsibility for developing a strategic and comprehensive vision for the hog sector, as requested by industry, is now deferred to the Pork Value Chain Roundtable. The Roundtable's Strategy for Canada's Pork Industry, dated May 2005, identifies environmental issues as a major concern and notes that action here could improve the sustainability of the pork sector. However, we found that only one of the 57 specific actions identified by the Roundtable addresses environmental matters.

8.63 Based on previous audit observations and on commitments from Agriculture and Agri-Food Canada dating back to 1998, we expected that the Department would have developed a hog environmental management strategy. In our view, it is still not clear if the Department has a comprehensive, strategic approach to help farmers reduce the environmental impacts of hog farming and work toward a sustainable hog industry.

8.64 Agriculture and Agri-Food Canada leads programs to reduce the environmental impacts of hog farming. Agriculture and Agri-Food Canada has made progress in gathering baseline data and has led many programs and initiatives to address the environmental issues arising from hog production in Canada. In 2002, the Department partnered with Statistics Canada to conduct a Farm Environmental Management Survey. About 16,000 farms, including hog farms, were surveyed to collect baseline information. A follow-up survey is planned for 2007. This information will be used by the Department to measure the impacts of agriculture on the environment through the National Agri-Environmental Health Analysis and Reporting Program (NAHARP).

Agri-Environmental Indicators

In response to the need for information and to assess the impacts of agricultural policies on the environment, Agriculture and Agri-Food Canada is developing a set of science-based indicators. The indicator for the risk of water contamination by nitrogen states that between 1981 and 2001, overall nitrate concentrations in water bodies in Canada increased by 24 percent.

8.65 Agriculture and Agri-Food Canada has started to monitor the environmental impacts of agriculture through NAHARP and the Farm Environmental Management Survey Program. We expected that the Department would also monitor the results of its programs in order to better direct its resources. However, it does not always do so, and therefore the Department does not know if its programs are achieving their expected results.

8.66 For example, in 2000, Agriculture and Agri-Food Canada announced $2.3 million for the Livestock Environment Initiative to assist industry in addressing environmental concerns. The initiative wrapped up with a symposium that shared research findings. However, the Department did not follow up to verify whether the objectives of the program were met, including development of pilot projects or the transfer of technology.

8.67 Further, Agriculture and Agri-Food Canada announced it would spend $300,000 to develop a standard to promote responsible environmental management of hog operations in Canada. The standard was published in March 2004 by the Canadian Standards Association. However, during our audit the Department could not provide plans to monitor or assess the implementation of this standard to determine if it has had an impact at the farm level. Department officials advised us that a proposal to test the implementation of the standard on a pilot basis was approved in principle on 16 May 2005.

Agriculture and Agri-Food Canada is not effectively communicating or monitoring its beneficial management practices

8.68 Agriculture and Agri-Food Canada and Environment Canada also develop and fund mitigation technologies and beneficial management practices for hog farming. Although we examined research activities conducted at Environment Canada's National Water Research Institute, our audit focussed mainly on the programs developed at Agriculture and Agri-Food Canada because they are designed to produce results at the farm level. Exhibit 8.8 provides an example of a beneficial management practice developed by Agriculture and Agri-Food Canada.

8.69 Environment Canada conducts research related to hog farming primarily through its National Water Research Institute. Research activities to date have focussed on the impacts of manure on water quality and are undertaken with a variety of stakeholders, including Agriculture and Agri-Food Canada. Environment Canada works to identify important emerging issues, including investigating the cause of the beach closures at Lake Huron. However, scientists indicated that there are still gaps in knowledge about the impact of hog farming on the environment and that beneficial management practices in this area need more work.

8.70 Progress is slow. Agriculture and Agri-Food Canada is working to deliver beneficial management practices to hog farmers through its Environmental Farm Plan Program and its National Farm Stewardship Program. The Department informed us that it can take up to 10 years to develop and implement such practices at the farm level. It provided a list of 10 categories of beneficial management practices for hog farming that have been developed with stakeholders. The implementation of the National Farm Stewardship Program, which provides funding to farmers for implementing beneficial management practices, hinges on the voluntary completion of environmental farm plans by farmers. The Department projects that about 66,530 environmental farm plans will be developed or updated by 2008. Currently, about 25 percent of this total have been reviewed and accepted under the Agricultural Policy Framework, and those that were completed prior to the framework are under review for approval. Information provided by the Department notes that delays in the development of environmental farm plans can lead to delays in other programs, including the National Farm Stewardship Program. (See photograph)

8.71 Beneficial management practices are not effectively communicated. In 1999, Agriculture and Agri-Food Canada funded a research project to look into fostering a sustainable hog industry. The report recommended that beneficial management practices be incorporated into a database to promote their implementation by hog farmers. Accordingly, we expected that the Department's beneficial management practices would by now be made available on a database that farmers and others could readily access. This database could also assist Environment Canada with its compliance promotion efforts. However, we found that no central database of this nature is available. Recent surveys of farm practices found that many farmers are still not using beneficial management practices.

8.72 A recent Statistics Canada study indicates a wide variation among regions in knowledge and implementation of beneficial management practices to deal with hog manure. For example, in 2001, 95 percent of livestock farmers in Quebec were familiar with beneficial management practices for manure management, compared with 45 percent in Saskatchewan and 63 percent in Manitoba. Department officials told us that outside the prairie provinces, programming related to federal beneficial management practices is delivered by provincial governments and by third-party industry groups. On the prairies, these federal programs are delivered by Agriculture and Agri-Food Canada. The Department identified the need for a national approach to communication in this area and is currently developing consistent information for all provinces and regions. However, the Department currently cannot demonstrate that beneficial management practices and mitigation technologies are communicated consistently across the country or made readily available to farmers who need them.

A need to improve knowledge of beneficial management practices

In 2004, Statistics Canada noted "a real need for education and awareness of beneficial [management] practices" for manure management. It found that almost 40 percent of livestock farmers indicated that they were unfamiliar with beneficial management practices for manure management.

8.73 Agriculture and Agri-Food Canada does not know if the beneficial management practices it supports are cost-effective. The Department's 1999 research report concluded that it was necessary to be able to demonstrate results and feasibility for new technologies for manure management and treatment to ensure the widespread acceptance of these technologies by hog producers. During our audit, the Department was unable to provide information on what it would actually cost a farmer to implement beneficial management practices. Without important cost information, hog farmers are unlikely to implement innovative practices that could reduce the impacts of hog farming on the environment.

8.74 Agriculture and Agri-Food Canada does not monitor the uptake of its beneficial management practices. The Department has made progress in gathering baseline data on environmental issues related to hog farming through its Farm Environmental Management Survey and NAHARP. However, the Department does not currently monitor the implementation of these practices by farmers and cannot report on a national basis on the effectiveness of the practices it supports. Tracking which practices work well and where they work well on a national basis would ensure that the Department is allocating its resources effectively.

8.75 Recommendation. Agriculture and Agri-Food Canada should clarify its approach to addressing the environmental impacts of hog farming and clearly communicate the approach to all stakeholders, in order to encourage a sustainable hog industry. The Department should also effectively communicate its beneficial management practices and monitor their implementation.

Agriculture and Agri-Food Canada's response.

Agriculture and Agri-Food Canada accepts the recommendations of the Office of the Auditor General. The Department is developing a communications plan to address the Environment Element of the Agricultural Policy Framework. This includes communications to producers about environmental stewardship, farm planning, and beneficial management practices that relate to hog and other kinds of farming activities. To clarify the approach and communicate it to all its stakeholders, the Department will improve the Framework's Environment Element on its Web site. The site will provide national and provincial information, as well as appropriate links to program delivery agents. The link to ManureNet, a national Web site, will be made more prominent. This site is dedicated to manure management issues in Canada and provides information including research projects, acts, regulations, guidelines, fact sheets, and new technologies. The timeline for completing this project is March 2006. The Department also commits to improving the communication of its environmental strategy through the next Sustainable Development Strategy.

To communicate beneficial management practices, the Department will work to improve the availability of information for producers on relevant programs under the Agricultural Policy Framework. Direct communications with producers on beneficial management practices will also continue on a regional basis through provincial Environmental Farm Planning programs, and by provincial delivery agents of the National Farm Stewardship Program (NFSP). The timeline for completing this project is March 2006. To monitor the implementation of beneficial management practices, the Department will continue to collect information on implementation of these practices through delivery agents of the NFSP. Information will be stored in a national database. This information will also be used to support program refinements to foster increased implementation of the practices by all producers by March 2008. Through agri-environmental indicators, the Department will also continue to assess the broad impact of adopting beneficial management practices on the environment. Agri-environmental indicators are reported on a five-year basis, with the next report due in 2005.

Conclusion
8.76 Petitions have resulted in departments taking action on environmental issues. In order for the petitions process to be an effective tool, the integrity of the process must be maintained by both petitioners and departments. Petitioners can do this by clearly presenting their issues and questions and making certain that their facts are correct. Departments are responsible for responding in a timely manner and ensuring that all issues raised in petitions are clearly addressed.

8.77 As part of our monitoring role, we audited selected commitments made by Natural Resources Canada and Environment Canada in response to petitions. We found the following:


8.78 In our audit on the impacts of hog farming, we found that Environment Canada and Agriculture and Agri-Food Canada do not know if their programs and activities are reducing the impacts of hog farming on the environment. Specifically, we found the following:

Environment Canada met its commitment in its petition response for the Ontario region. However, the Department does not currently monitor or track its compliance promotion activities and cannot yet demonstrate that its efforts related to hog farming have resulted in an increase in farmers' compliance with the pollution prevention provisions of the Fisheries Act.

Agriculture and Agri-Food Canada has yet to clarify its strategic approach to addressing the environmental impacts of hog farming and clearly communicate the approach to all stakeholders, in order to encourage a sustainable hog industry. The Department has made progress in measuring the impacts of agriculture on the environment in general and has developed beneficial management practices and mitigation technologies to deal with the impacts of hog farming. However, it cannot demonstrate that these practices are communicated consistently and made readily available to farmers.