Essentially, the section outlines that, for agricultural feedstock to qualify for the Clean Fuel Standard, it must not come from a land base that was converted to agricultural production from forest, wetland, peatland, or high-biodiversity land after Jan 1, 2008.
“If new agricultural land expands into areas with high carbon stock such as forests, wetlands and peatland, this leads to additional greenhouse gas emissions. If it occurs in a highly biodiverse land, it can lead to lost biodiversity,” said the proposed regulatory approach. The government is still developing certification processes, but a third party would verify regulatory compliance.
Since it would be unrealistic to differentiate grain or other feedstock as it’s harvested “your whole farm unit would not be accredited as a feedstock supplier,” said Haerle. “There’s no farm facility that would be able to handle that.”
GFO released a statement on Sept. 18, opposing the land-use section of the Clean Fuel Standard proposed approach.
This land-use stipulation would prohibit “90 per cent of all farms across Ontario. If you cleared 1.2 acres within that time frame, you are disqualified,” Haerle explained.
Most of those farmers are not clearing large sections of land, rather converting sections of land into crop production that has the potential to sequester more carbon than unmanaged brush, he added.
The land-use stipulation “would foster imports coming in before domestic production being used,” he said. If U.S. farmers complied with the regulatory approach “those feedstocks would be preferred over the Canadian feedstocks. … That has to do with pricing of the commodity and accessibility at that point, because then they would have a stable supply.”
GFO is concerned that this approach will shut Ontario producers out of the biofuel marketplace, which is important to many producers.
“We have to remember that it’s not only the impact on ethanol and corn farmers, but it’s also the biofuel diesel which comes from soy, which would be impacted as well. And those are the two large commodities that are grown in Ontario,” Haerle said. Biofuels “have brought some stability to our production of corn and soybeans, and also a price level that’s more stable. With that disappearing, I don’t even know what alternative crops would be out there to offset that.”
Adding regulations that place additional stress or exclude agricultural contributions discredits the hard work farmers have already been doing to reduce their carbon emissions, Haerle said. “As farmers, we have done a lot on the environmental side to diminish the impact to the environment the last couple of years, and now the government is saying what you have done is not enough.”
GFO is in favour of most of the Clean Fuel Standard approach “as a benchmark of creating a stable, low-carbon fuel base. Of course we want to make sure that it happens in the proper manner,” he added.
However, for the Clean Fuel Standard to be workable for farmers “there has to be a strong discussion about scrapping” the land-use section, Haerle said.
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