Re: Canada-Ontario Agreement on Great Lakes Water Quality and Ecosystem Health

July 30th, 2026

Carla Torchia, Federal COA Secretariat
Canada Water Agency
510-234 Donald Street
Winnipeg, Manitoba
R3C 1M8

Carolyn O’Neil, Provincial COA Secretariat
900 Bay St.,
Toronto, Ontario
M7A 1Y4

Re: Canada-Ontario Agreement on Great Lakes Water Quality and Ecosystem Health

The National Farmers Union-Ontario (NFU-O) is an accredited farm organization representing sustainable farmers in Ontario and has advocated for farmers across Ontario since 1969. Members work together to achieve agricultural policies that ensure dignity and income security for farmers, while protecting and enhancing rural environments for current and future generations.

Despite billions of dollars invested in voluntary conservation and nutrient management programs in Canada and the U.S., agricultural nutrient runoff continues to cause toxic algal blooms in all of the Great Lakes, especially in Lake Erie. Mitigating problems like Lake Erie eutrophication and climate change requires moving beyond maximizing crop yields. Sustainability should become the primary goal of a renewed COA, with practices that prioritize long-term soil health, water quality, and environmental protection.

We understand that in order to work towards commitments, the COA recognizes and supports voluntary adoption of the 4R Certification Program through agricultural partnerships, education, and outreach, and that this functions through a Memorandum of Understanding (MOU) with Fertilizer Canada, Ontario Agribusiness Association, OMAFA, Grain Farmers of Ontario, Christian Farmers Federation, and the Ontario Federation of Agriculture.

In 2024, NFU-O published a Nutrient Management Report, examining farmer attitudes and perceptions of nutrient management, including the risks and solutions to water contamination from animal manure and the agricultural application of nitrogen and phosphorus fertilizer. This study found that less than 15% of conventional crop farmers regularly rely on OMAFA’s current nutrient management guidelines and the vast majority take commercial fertilizer suppliers’ advice at face value, in spite of the evident conflict of interest. So long as efficiencies are tied to maximizing yields, the 4R approach can perversely lead to an increased use of fertilizers, even though increasing application has shrinking returns and offers little financial benefit to farmers themselves. Farmers need support in cultivating best management practices through publicly accountable services with well trained agrologists capable of assisting farmers in calculating the most efficient and sustainable nutrient applications for their fields (including independent, i.e. noncorporate, advice on the right time, rate, source, and placement). Incentives and free soil testing are also a necessary baseline requirement to support nutrient reductions and bring less interested farmers into the conversation.

NFU-O survey data also revealed that crop farmers spend, on average, one-fifth of their input costs on fertilizer and many shared concerns about the expense. This suggests that both the environment and farmers would benefit from expanded education campaigns on practices/methods that reduce the total amounts of fertilizers required to grow their crops. These campaigns should provide free and accessible training on the most up-to-date agricultural conservation practices. Many farmers were interested in exploring the possibilities of “least cost crop production” and farming for maximum profit rather than for maximum yield. Extensive, long-term support is required for farmers in: understanding and quantifying emissions; using fertilizer with maximum efficiency and effectiveness; optimizing and reducing use of other inputs; optimizing livestock systems; managing water and improving soils; and accessing agronomic advice independent of agribusiness corporations.

As an outcome of these findings, we would like to see the following continue in Annex 1 (Nutrients) in the next agreement, with suggested modifications based on our study findings. 

As producers continue to struggle with increasing costs of production, the NFU and the NFU-O request that COA administrators work to meet phosphorus reduction targets by providing increased funding for educational and farmer-to-farmer knowledge sharing opportunities that focus on least cost production, run by partner organizations. This should also include education around the shift from synthetic fertilizer overapplication towards nutrient management strategies that are both financially and environmentally beneficial.

Additionally, increased structural support should be supplied for independent, non-commercial technical assistance. Provide for wording in the Nutrients Annex that shifts away from reliant third-party commercial certifications and prioritizes funding publicly accountable advisory professionals and independent agronomists. Explicitly provide capacity-building funds within the COA for Conservation Authorities to create permanent, multi-year positions for watershed agronomists, and for free soil testing for participating farmers. 

Sincerely,

Josh Suppan

President, National Farmers Union – Ontario

josh@nfuontario.ca

(705)738-3993 ext 2

Jenn Pfenning

President, National Farmers Union

pfenning@nfu.ca

306-652-9465