Ontario Soil and Crop Improvement Association (Ontario Soil and Crop Improvement Association) on April 23, 2020

1. Do you support Lake Simcoe Watch’s recommendation that the Government of Ontario should develop a plan to reduce Lake Simcoe’s phosphorus pollution to 44 tonnes per year by 2026? If no, do you support the achievement of the 44 tonne per year target by a later date? If yes, please specify the date.

Yes, OSCIA agrees with the target reduction of 44 tonnes per year by 2026.

2. Do you support Lake Simcoe Watch’s proposed actions to reduce Lake Simcoe’s phosphorus pollution? If no, please explain why not and outline alternative actions that you believe should be taken to reduce Lake Simcoe’s phosphorus pollution?

OSCIA is generally supportive of the proposed measures, but can speak only to the agricultural practices being proposed.

Uptake on water course naturalization can be limited as it requires farmers to stop production on significant acreage, particularly if the goal is a 30m buffer along all watercourses and fish habitat. Fairly compensating farmers for the loses in income could be prohibitively expensive. While OSCIA is supportive of this action, the challenges in implementation must be recognized.

The Phosphorus Reduction Efficiency percentages for streambank stabilization and streambank fencing are significant and may be more achievable that 30m buffer areas. Encouraging good agronomic practices such as crop residue management, nutrient management, cover crops and reduced tillage should also be encouraged, and may also see higher implementation rates than large buffer areas.

It should be noted that there is significant history (i.e. 30 years) of delivering agriculturally focused cost-share programs in the Lake Simcoe watershed. As a general statement, the farm community demonstrated significant willingness to participate and adopt further best management practices; however, more recent programs (i.e. last five years) have seen relatively lower uptake by the agricultural community. Any funding programs must be strongly aligned to the diverse production practices of the Lake Simcoe watershed. It will also be critical to tailor funding opportunities to the needs of the growers in the Holland Marsh.

3. Do you agree that the Development Charges Act should be amended to permit the Government of Ontario and Lake Simcoe municipalities to levy development charges to recover 100% of their costs of reducing Lake Simcoe’s phosphorus pollution? If no, please explain why not and outline how you believe the pollution reduction measures should be paid for.

Based solely on the information provided in the discussion paper, OSCIA agrees that levying development charges seems a reasonable way to offset the costs of improving water quality in Lake Simcoe.

4. Please provide any other comments about Lake Simcoe Watch’s report: Cleaning Up Lake Simcoe: A Discussion Paper.