The National Farmers Union in New Brunswick (NFU-NB) welcomes the opportunity to provide feedback on the proposed changes to the Livestock Operations Act. We would like to begin by saying that the National Farmers Union in New Brunswick generally welcomes changes to the current Livestock Operations Act (LOA), and that we generally agree with the proposed changes and the approach the Department of Agriculture, Aquaculture and Fisheries has taken so far in seeking consultation and promoting awareness of the proposed changes.
The NFU-NB has identified some areas of concern and we would suggest more consideration be given to these areas before proceeding with the proposed changes:
Beneficial Manure Management Practices (BMMP’s): If BMMP’s are implemented new entrants will need to also be educated and guided on their use. The NFU-NB would like to see the establishment of the BMMP’s and a plan for consultation and education around these before proceeding with the proposed changes.
Nutrient Management Plan (NMP): Understanding that NMP’s take considerable effort on the part of the applicant and the Department, a program to assist new entrants and existing operations in the development of NMP’s could be implemented. This would ensure proper spreading and distribution of manure, while removing some of the burden from the farmer and the applicant. All of this considered, if the proposed BMMP’s are developed, delivered and enforced with success, the benefits from an NMP should still be achieved.
Building and Expansion Permits: This area of the proposed changes likely requires the most consideration of all. It makes sense that governing new livestock facilities and expansions are done at the local level of government, but at the current time it seems many Government services are being offloaded onto Regional Service Commissions, LSD’s and Municipalities and this may not be the time to make the changes proposed in the new LOA. The proposed transition requires more thought and clarity of process.
Minimum Setback Distances (MSD): The NFU-NB represents farmers of all size operations and MSD’s may need to be implemented in a way that they are not a “one size fits all” application. It will likely be hard to reach any kind of a consensus around MSD’s, but the current distances do not allow for much consideration of smaller operations. MSD’s for spreading manure around sensitive areas is a step in the right direction for providing guidance and environmental consideration, but some identification of these areas and awareness should be included in the BMMP’s.
Large Livestock Operations: NFU-NB agrees with that the registrar should hold the right to impose additional requirements on large operations. This would serve to protect the industry, communities and the environment. Some outline of what these additional requirements maybe should be developed in an effort to ensure fair implementation across all size producers.
Expected Outcomes: The NFU-NB is concerned one unexpected outcome of the proposed changes is that department staff may be less familiar dealing with livestock operations and potential issues when new applications are no longer required (less paperwork may mean less familiarity). This may pose challenges when a time arises that issues need to be dealt with (specifically issues relating to manure handling and storage).
