Senate Committee on Agriculture
1 Capitol Square
Columbus, OH 43215
November 19, 2013
Chairman Cliff Hite and Senator Bob Peterson:
I write to you today on behalf of the Ohio Ecological Food and Farm Association (OEFFA) regarding the proposed legislation on nutrient management (Senate Bill 150).
OEFFA was founded in 1979 and has more than 3,000 farmers, consumers, retailers, educators, researchers, and other members who share a desire to build a healthy food system that brings prosperity to family farmers, meets the growing consumer demand for local food, creates economic opportunities for our rural communities, and safeguards the environment. OEFFA also operates one of the country’s oldest USDA accredited organic certification agencies and currently certifies 816 operations.
In recent years there has been growing public pressure to address the pervasiveness of algae blooms in Ohio’s waterways caused by farming. We appreciate Senators Hite’s and Peterson’s efforts to initiate conversations in order to address nutrient management deficiencies. Although registering and tracking the use of commercial fertilizers is a necessary step in taking control of problems surrounding nutrient pollution, we recognize that this alone will not resolve them. Specifically, there are two issues with the proposed legislation:
1. Certified organic farms should have the option to provide a valid certificate to the Ohio Department of Agriculture in lieu of the fertilizer applicator license.
The proposed legislation is aimed at identifying and resolving nutrient pollution causing algae blooms in Ohio lakes and other waterways. Certified organic growers applying fertilizer to their land may be subject to licensing requirements under Senate Bill 150. Due to the USDA National Organic Program’s (NOP) rigorous standards (NOP §205.200), which require farmers to maintain or improve the farm’s natural resources, regulating organic growers is misdirected and an inefficient use of state resources.
Certified organic farmers are required to complete Organic System Plans (OSP) and annually undergo onsite inspections and submit records for review. Every OSP must demonstrate that a farmer has taken steps to meet soil fertility and crop nutrient management standards that maintain or improve the condition of soil, minimize soil erosion, and prevent to contamination of water (NOP §205.203(a)(c)(d)). Organic System Plans include detailed information regarding the date and rates of application commercial soil amendments, compost, and manure, thereby superseding the reporting requirements in SB 150. Further, organic producers must demonstrate how contamination to soil or water was prevented (NOP §205.203(c)(1)). Other requirements under the organic standards include maintaining or improving soil integrity by implementing crop rotation, and utilizing cover crops (NOP§205.205).
Finally, if organic farmers incorporate commercial fertilizers in their operations, they must use substances approved for organic production (NOP§205.105, NOP§205.601(j)). Organic fertilizers usually contain many different nutrients that are in significantly lower concentrations than chemical fertilizers and release more slowly into the environment. Even if a farmer utilizes a synthetic fertilizer allowed under organic standards, it is in combination with other conservation practices required under the standards to mitigate any adverse impacts on water quality.
2. Fertilizer applicator licensing should be expanded to include manure.
Agriculture is the number one cause of contamination of our waterways. Nutrient runoff from over application of manure is a known pollutant, and to reduce such pollution in a
meaningful way, additional standards for manure application must be put in place.
A 2010 Columbus Dispatch article entitled “Manure, Pesticides Take Ohio, Waterways” ran shortly after the peak of toxic algae blooms at Grand Lake St. Marys in Mercer County, reporting that the number of cows, hogs, and chickens on farms in the county has more than doubled in 20 years. Altogether these operations, in this one county, produce more than 1.6 million tons on manure each year.
As written, SB 150 will not effectively solve the nutrient runoff issue because it is not regulating manure, the other contributor to the problem. For instance, loopholes in current regulations omit smaller manure distributors and applicators from registering with the state.
3. Without substantiated and regulated methods for reducing nutrient runoff, SB 150 will fail to effectively tackle algal blooms in Ohio.
Although creating fertilizer application registrations is a good first step, it will not result in meaningful reductions of nutrient runoff. Other solutions currently exist to help mitigate nutrient pollution, including strong conservation practices and soil testing as a basis for nutrient management. Ohio legislators should look to these strategies and require or incentivize reductions in nutrient pollution from farming.
Thank you for your consideration of these important issues.
Policy Program Coordinator
Ohio Ecological Food and Farm Association
41 Croswell Road
Columbus, OH 43214
Phone: (614) 421-2022 Ext. 208