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are woefully inadequate in Manitoba to reduce or prevent over-application of nutrients in manure to farmland. They can be found in the Livestock Manure and Mortalities Management Regulation under the Environment Act at the Manitoba legislature website under consolidated statutes and regulations.  
In a report to the Clean Environment Commission's review of the sustainability of the hog industry in Manitoba conducted in 2006/07, soil scientists reported that the average annual uptake by crops of phosphorus in Manitoba is 20.47 lbs/acre measured as P205 with the Olsen soil test method.  
The regulation on phosphorus levels in Manitoba farmland allows producers to apply manure at rates to meet the nitrogen requirement of crops each year until the residual phosporus in the soil reaches 60 ppm (parts per million) as measured by the Olsen soil test method. 60 ppm equals 276 lbs of P205 phosphorus PER ACRE. This conversion factor can be found in the Farm Practices Guidelines for Hog Producers. To convert ppm to lbs/acre of soil test P, multiply ppm x 4.6.  
 
Once soil test levels reach 60 ppm, then application rates are allowed to occur at twice the amount of phosphorus a crop is expected to use that year. When soil test levels reach 120 ppm (over 500 lbs/acre ), then application rates are supposed to be restricted to only the amount of phosphorus a crop will use that year. When soil tests measure 180 ppm (over 800 lbs/acre) then manure application is supposed to stop.  
 
The regulation also allows producers to apply more phosphorus than a crop can use in a single year - up to 5 years worth as long as no manure is applied for that number of years. So if a producer applies a 3 year amount in a single application, no manure can be applied for the next 3 years.  
 
Mike Telliet, former Environmental Officer for the Manitoba Pork Council has stated that manure application equipment cannot be calibrated to deliver liquid manure at rates that a crop can use in one year so operators have told him that they routinely apply multiple years worth of phosphorus and then don't apply for a number of years.  
 
There are a number of obvious problems with this regulation.  
 
First, scientists have shown that when soil test levels approach or reach 60ppm/acre (276lbs), there is an exponential loss of phosphorus to the environment and water bodies. The actual rate of loss depends on the type of soil as some soils lose phosphorus at higher rates and at lower soil concentration levels.  
 
Second, soil tests measure labile P. Labile P is the phosphorus that is available to be used by the plant at the time the soil test is taken. This amounts to about 10% of the amount of P that is in the soil. About 90% is non-labile which means it is bound in the soil but can become unbound depending on amount of water, temperature, microbial activity etc. during any growing season.  
 
This means that the Manitoba regulation (LMMMR) allows for loading of phosphorus in farmland to 2760 lbs/acre BEFORE there is any restriction on phosphorus application and ultimately to over 8200lbs/acre before no more phosphorus can be applied.  
 
Third, phosphorus builds rapidly in soil but takes a very long time to deplete.  
 
Fourth, eutrophication of water bodies and algal growth is spurred by very small amounts of dissolved phosphorus.  
 
Fifth, the Lake Winnipeg Foundation has been monitoring phosphorus levels in runoff (spring and rain events) and has compiled data showing "hot spots" in the Red River Valley where there is an abundance of intensive livestock operations (hogs, cattle and dairy). This P ends up in Lake Winnipeg.  
 
Sixth, the Clean Environment Commission report on the sustainability of Manitoba hog production acknowleges that in the municipalities of Hanover and La Broquerie where the hog industry is concentrated, are close to or exceed the saturation point allowed. Of course there will be significant losses of P to waterways, lakes etc.  
 
Seventh, when farmland is saturated/flooded for 10 days or more, not only is the available (labile) P dissolving in and moving with these flood waters, so too is some of the bound P as it will become unbound.  
 
Eighth, need I ask the obvious question which is "if the average annual crop use is 20.47lbs/acre, why does the regulation allow for obscene levels of phosphorus loading on farmland (over 800 lbs/acre soil test labile P)? "  
 
Ninth, while P will bind in soil, overapplication in a single year can lead to loss with spring runoff, flooding and rain events. Why does the regulation allow for up to 5 years worth in a single application? Refer above to Mike Telliet's comments.  
 
Tenth, government knew well before the massive expansion of the hog industry that the imbalance of nitrogen and phosphorus in hog manure would lead to P build up in soil and transport loss to surface water. Even so, the best government would do was to regulate P in the way outlined in the LMMMR. Technical REview Committees and soil test companies have considered 30-40lbs of P in soil to be high since the late 1990's. (TRC reports are available in the public registry. Check out the early ones. It's there.)  
 
To add to the problem, the Province passed Bill 34 in 2018 where it removed the special Red River Valley designation from the Environment Act which restricted hog industry expansion in this region and required the use of manure waste processing facilities to remove P and put it in a form where it could be transported out of the region. Government also changed the Planning Act to weaken the rules on expansion without conditional use approvals by municipal governments and made it more difficult for people and municipalities to reject proposals for new operations to set up in their areas. The livestock industry now has the ability to appeal a rejection by a municpal council or planning authority or the conditions that they might have imposed on approving a conditional use to the Municipal Board. (Bill 19) The LMMMR was also changed to allow earthen manure storages to be built on surface watercourses by creating a new category called "ephemeral drains" and allowing builds on these drains. Still a surface watercourse nevertheless. But, if it meets the ephemeral drain definition, it's all good.  
 
The problem with these regulations fundamentally comes down to the fact that intensive livestock operations produce too much waste by too many animals on too small a land base and aren't required to have enough spread acres to use the phosphorus contained in the manure at rates that the crop can use up in a growing season. Phosphorus is allowed to build up in soils to alarmingly high levels because the regulation in essence is an environmental subsidy to industry. We are all paying the price for water pollution and eutrophication caused by an unsustainable industrial production model - especially for hogs.  
 
Proper riparian management is important. If animals are properly grazing there shouldn't be buildup of P. What researchers have also found is that buffer zones aren't that effective because they can become overloaded and dead plant tissues release 10 times more P during spring runoff than results from soil erosion.  
 
Preserving and restoring wetlands is also important. But this government has also made it easier for farmers to drain land through regulatory change.  
 
Because it takes so long for P to deplete in soil, the logical and only sensible course of action to prevent degradation of surface waters is to PREVENT buildup in soil in the first place.  
 
Clearly that is not what the regulations support. The LMMMR is a licence to pollute because it is cheaper for the intensive livestock industry to do so than to secure enough land and manage it properly so that P does not build up and be available for transport into surface waters.  
 
We now have a completely foreign-owned hog production company (Hy-Life Foods) expanding its operations in this province. Started out in the Red River Valley. Now owned by foreign investors. About 6% of the pork produced in Manitoba is consumed here. The rest is exported. Why wouldn't foreign owned companies want to set up shop here. Take the profits, leave just enough wealth in Manitoba to ensure production continues ( a few jobs) and leave Manitobans with the water quality mess we are experiencing.  
 
Before we go to the defensive place as farmers, government has also done a crappy job of dealing with Winnipeg's sewage problem. Here too, the regulation fails as it allows 50 times what is considered to be the environmental threshold for P release into the river. P sediment levels in Lake Winnipeg are high and will continue to increase over time if the allowable discharge levels are not reduced and the City continues to not deal with it's wastewater treatment problems.  
 
So too with so many community's discharge of wastewater into rivers all over the province which ultimately drain to Lake Winnipeg and contribute to the eutrophication of surface water province-wide.  
 
Government has made it impossible for the public to verify what is actually happening on-the-ground with nutrient levels on farmland. The LMMMR requires intensive livestock operations to file manure management plans but the nutrient levels are considered proprietorial information. Even the Clean Environment Commission when doing its hog industry review did not require their release to determine how well or not the industry was doing in complying with regulations.  
 
So, when people who challenge the myth that Manitoba has the most stringent nutrient management regulations in North America and that the livestock industry is not polluting are accused of spreading misinformation and lies, I ask that the facts I have shared be considered.  
 
It is obvious there is a problem. All of us are a part of the problem but there are sectors that need attention and immediately before there are no solutions. Once the nutrient loading is too high, it will take hundreds of years to resolve it. I don't want the children and future generations to be saddled with a problem created for the sake of multinational profits and environmental subsidies.  
 
And, by the way, I've been a mixed farmer most of my life.

All of this can be easily solved by soil testing, plant tissue testing and analysis and testing of waterways. Without this data it is improper to make further assumptions about what nutrients and pollution come from where or what nutrients are being efficiently used by crops, because without a historical dataset one cannot know. Without data and proper professional analysis everything else is supposition which is a dangerous thing.  
For my small mixed farm I have all of this data for the past 15 years (and am continually building upon it) , that strongly supports the methods employed by my family and shows increasing soil organic matter , increased top soil depth , improved crop uptake and efficiency and increased biodiversity. I know what’s going on in my soil , my plants and my waterways and have the confidence to continue to improve my crops, my soil and reduce our environmental footprint.  
 
Edited by Farmergeorge, 2022-09-12 15:49:48

to hear , that not everyone has their head in the sand. Calling people a liar, makes some people feel better about themselves, but does nothing to fix the problem...

Get your facts straight and be capable of producing documented evidence to substantiate your claims. I have documentation that supports how and why we make the decisions and employ the methods that we use and proves our farm to be sustainable and ecologically sound. I have the support of Manitoba Habitat and heritage supporting my methods and the wildlife that we protect on my farm.  
What do you have? An Ill educated opinion..  
 
Edited by Farmergeorge, 2022-09-12 19:20:57

did a great job explaining the facts to you.. We all have an opinion, unfortunately yours is wrong....

Well my soil and plant tissue testing, analyzed by certified agronomists, the cleanliness of waterways on my land and the abundance of biodiversity, insects, birds, wildlife and wild plants and flowers on our farm says otherwise .  
Without knowledge derived from data that has been reviewed and built over the years it is impossible for one to make informed comment .

that testing is important. So, what do you think about how government is handling industrial livestock operations and phosphorus with its regulations? Do you think that industry compliance with these regulations will lead to no pollution from the industry? Soil testing is required under these regulations. If soil test results show phosphorus loading is high and there are no other acres on which to spread manure, how can one argue that the environmental footprint of these operations will be improved solely through testing and monitoring?  
Also, would you agree that soil test results from intensive livestock operations should be make public so that we have clear data to work with to make sound public policy?

are being put into the same category as industrial food producers. I don't call industrial food producers farmers. I would put Farmergeorge in the category of responsible farmer. We have a nutrient pollution problem in this Province and country which has been caused by industrialized production methods which the government supports. It's great that farmergeorge has improved the soil, biodiversity and understands his nutrient cycling through testing and documentation. It is likely that he does not have an emissions problem. Nor do I.  
 
Not like industrial hog operations for example, using open earthen manure storages where government assumes off the top that 30% of the nitrogen contained in these storages will volatize. (see application forms to build a hog factory where calculation of the spread acre land base needed is calculated) These emissions are Greenhouse gases. The Clean Environment Commission recommended that storages be covered to reduce the amount of emissions. Industry opposed this because it cost money. The government does not require these storages to be covered. Emissions also i:nclude methane, another potent GHG.  
 
True farming is a complex balance between nature and human activity and was sustainable for 10 thousand years until we moved to "efficiency of scale" and industrialized models of producing food where increasing yields and “efficiency” in animal raising became the measure. Science can be a useful tool in understanding this complexity and achieving a balance. The source and motive for the science and recommendations must always be questioned.  
 
Humanity has a big problem that requires understanding the reality of what is happening around us and finding out what we can do together and doing our part.  
 
Unfortunately, INDUSTRY is more concerned with maximizing profits for shareholders than being responsible to the well-being of people, communities and the planet which sustains us all. Look at what is happening in the Amazon. Look at what is happening here.  
 
I used to think that being a farmer was an honourable thing to do. That’s part of the reason I do. But once I understood how farming has transformed the world and so denigrated it, I can no longer feel honourable when lumped into the larger general category of farmers.  
 
However, when defending farmers, I defend farmers not industrial agriculture. Farmergeorge appears to understand the difference. We need to not get caught up in defending agriculture as a whole in order to be clear to others about what we do and what our o:bjectives are.