Canadian Institute for Business and the Environment
Fisherville, Ontario, Canada
Tel. 416 410-0432, Fax: 416 362-5231
Vol. 15, No. 12, March 31, 2011
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We open this issue with a fracking flap and we close it with a story about the non-existent spilt milk regulations. What other environmental publication gives you that kind of breadth?

In between the fracking and the spilt milk we have a feature which we originally hoped would address the question of 'Do we have enough land to support a switch from fossil fuels and fossil carbon based products to renewable products from biomass?'. We knew it was a big topic but we had no idea how big. So we have begun to tackle it in this issue and will return to it at an early date. But we have already begun to discover, as we suspected, that those who claim that we cannot switch to biofuels because it will increase food shortages and push up food prices may not be correct. Even last year's food price spike probably had little to do with bioethanol, as many critics have suggested. So, for now at least, long live biofuels and bioproducts as at least a partial solution to the crisis of climate change that continues to be a significant global threat.

We like to think that GL helps to provide information about the environment and sometimes about other things. A meglemma is one of those other things. See our biofuels introduction for details! Our biofuels section in this issue reviews reports on land use changes, food prices, global food policy, food commodity prices, and greenhouse gases from land use changes. Our review is far from definitive but it does suggest that at least a certain percentage of our energy and material needs being met from biomass may be sustainable. We also review an Agriculture Canada report on the sustainability of Canadian agriculture.

We get letters and for this issue we received a letter from the Federal Environment Minister's office about the biodiesel mandate regulations that we referenced in our last issue. We are pleased with the Minister's response and we are also delighted that his office reads GL so diligently. We also review the movie celebrating David Suzuki's 75th birthday, we look at reuse of waste materials, which a US Inspector General says may not be so beneficial, we review, somewhat unfavorably, the dark spring due to toxic substance runoff from the urban snow pack, and we give our friends at ECOCanada some heck for suggesting that flying cars are an environmental technology. What an issue! We hope you have as much fun reading it as we did writing it and we, we hope with you, look forward to the next issue which will look at environment in the election campaign, IF there is any environment in the election campaign. If not, there is much for us to review, and there will be even more of you keep those letters to the editor coming to

We have some new initiatives planned for Gallon Environment Letter this Spring. For a quick preview, bookmark and get a preview of one of our new initiatives!


Most of our readers will have a general familiarity with the term "fracking" - the extraction of additional oil or gas reserves from underground reservoirs by breaking up the rock while it is still underground through injections of steam, sand, and chemicals. While perhaps not technically precise, one might imagine that the natural gas or crude oil is trapped in bubbles and cracks within the rock. By breaking up the rock the natural gas or oil is released and will find its way to the wellhead and ultimately to the users of the fuel.

What many Canadians may not know is that fracking, an abbreviation for fracturing of the rock, can involve the use of all kinds of chemicals, many of which may be water pollutants and some of which may be carcinogens or worse. But before the industry bombards Gallon Environment Letter with emails telling us that fracking fluids are safe, approved by governments, and blah blah blah, let us state clearly that we have no idea whether fracking fluids are environmentally safe or not because, for the most part, we do not know what they are. Maybe they are safe and maybe they are not.

There is a solution and, perhaps surprisingly, it may soon be implemented in Texas and the oil industry appears to be supporting it.

The Texas legislature is currently considering a Bill, HB3328, "Relating to the disclosure of the composition of hydraulic fracturing fluids used in hydraulic fracturing treatments." It looks like the Bill will become law because it is being supported by the environmental ngo Environmental Defense Fund and the oil and gas industry.

GL's question: Why does the industry need legislation to disclose what chemicals it is pumping down holes into the shale rock and other semi-permeable layers that hold some additional oil and gas? There are probably at least two answers. One is that industry likes a level playing field - we won't tell until everyone tells, and there are always a few companies that refuse to provide information until forced to do so by the strong arm of the law. In the case of fracking chemicals, we really cannot see why the we won't tell until everyone tells is so crucial, especially if the chemicals are as safe as the companies claim. However, there is a second reason that may be more important. Bill HB3328 includes some protections on how the companies disclose and on how they need not disclose in the case of 'trade secret' chemicals. But at least they have to apply to a government commission to win approval of the 'trade secret' clause.

[Amusingly, the Commission they have to which they have to apply is the Railroad Commission of Texas. We hope that is a historic name for the Texas regulator of the oil and gas industry, not a description of the way they operate.]

Some environmental ngo's are critical of Bill HB3328 but some are supportive. The critics say it does not go far enough while the supporters say it is a good first step. GL would position itself among the latter group but would still ask: Why does the industry have to wait for legislation?

Canada's Talisman Energy, through its US subsidiary, states:
"Talisman Energy USA supports legislative efforts that facilitate disclosure on a well-by-well basis that includes the identification of additives by name and Chemical Abstract Service Numbers with protection within the limits set forth in federal law for confidential business information. Additionally, our view is that the most accurate way to disclose information on the constituents of hydraulic fracturing fluids is to provide the concentration of each additive and chemical as a percentage of the total sum of all constituents including carrier fluid and proppant. As such, we believe that H.B. 3328, as introduced by Texas State Representative Jim Keffer on March 10, 2011 offers a constructive framework for disclosure, and we support the bill."

So Talisman and the rest of the industry - why are you waiting for state by state and province by province legislation? And why don't you start disclosing the fracking chemicals you use in Canada without waiting for Canadian legislation? Surely Corporate Social Responsibility includes taking some leadership on some environmental issues, including this one, without waiting for government to tell you how to run your business?

Colin Isaacs

Paid subscribers see link to original documents and references here.

Many Canadians will recall Linda Keen, formerly head of the Canadian Nuclear Safety Commission until she was fired by the House of Commons because she wanted to protect us from the leaking Chalk River reactor, and replaced as Canada's chief nuclear safety officer by that esteemed nuclear expert Dr. (in his own mind) Stephen Harper. Even the NDP voted for that stupid motion, something for which GL suggests they should not be forgiven.

Linda Keen recently appeared on a CBC radio current affairs program where she was asked whether it was necessary to adopt stringent safety for Canadian nuclear facilities since the reactors weren't in locations likely to have earthquakes or tsunamis. She replied that it was better to take a holistic approach. We would like to see one of the major parties promise in this current election campaign to reinstate Linda Keen as head of the CNSC or in some other important public policy role.

However, the theme of this issue of GL is food versus fuel, not nuclear safety. The food versus fuel debate also requires holistic thinking. For example, the environment, not just prices and not just land, should be in the debate. A couple of years ago a paper in Science which called the food versus fuel situation a trilemma: food, fuel and the environment. In fact it is probably a meglemma, intersecting with globalization, trade and debt, poverty, land tenure, politics, population, innovation, corruption, pollution, climate change, wildlife, urbanization, education, racism and many other direct and indirect complexities. Our articles this issue may help to explain why.


A report from the International Energy Agency Bioenergy Collaboration, released in March 2011, concludes bioenergy is necessary for meeting global climate targets in the long term even if the benefits in the short term are not significant. With good policies and proper management of bioenergy plantations, food and fuel can be compatible. Principal author Berndes Göran, Associate Professor of Chalmers University of Technology, Sweden, used computer models of land use changed developed at the university. He identifies the main opportunities for reducing fossil-fuel carbon dioxide as energy efficiency and transitioning to alternative sources of energy and materials. Reducing fossil fuel energy includes "increasing the sustainable use of biomass for the production of biomaterials, heat and power, and for transport."

Much of the debate about food and fuel relates to changes of land use. Currently land use changes due to deforestation and expansion of agricultural production account for 15% of global emissions of greenhouse gases. Globally only about 1% of agricultural land is used for biofuel crops but policies are incentivizing and mandating increased use of biofuels.

For bioenergy which includes biomass for gas and liquid fuels, both direct and indirect land use changes are involved:
"• Direct LUC (dLUC) involves changes in land use on the site used for bioenergy feedstock production, such as the change from food or fibre production (including changes in crop rotation patterns, conversion of pasture land, and changes in forest management) or the conversion of natural ecosystems.
• Indirect LUC (iLUC) refers to the changes in land use that take place elsewhere as a consequence of the bioenergy project. For example, displaced food producers may re-establish their operations elsewhere by converting natural ecosystems to agriculture land, or due to macroeconomic factors, the agriculture area may expand to compensate for the losses in food/fibre production caused by the bioenergy project. A wide definition of iLUC can include changes in crop rotation patterns and/or intensification on land used for food or feed production."

As well as diverting land from food production, LUCs also affect greenhouse gas emissions. Changes may decrease or increase emissions e.g. cultivating land which has large carbon stocks in soil, trees or vegetation may release carbon to the atmosphere while planting annually cropped land to bioenergy perennial grasses which use little fertilizer can store more carbon. Not all bioenergy requires LUC. Examples are energy from postconsumer wastes such as food waste including fish and meat, which normally would have been sent to landfill, or straw which may be burned currently. Using wet waste for bioenergy may also have the benefit of avoiding methane emissions as the stuff rots. Using waste for biofuels can be regarded as positive in the short-term although a longer term perspective might put bioenergy at a disadvantage: e.g. "waste" wood from forest harvest might have even greater carbon benefit if left in the forest to add carbon.

Some of the issues addressed in the report are:
Some ideas for policy development include:
IEA Bioenergy is an international collaboration with work carried out through a series of Tasks, each having a defined work programme. Each participating country which, including Canada, makes both a direct financial and in-kind contribution (e.g personnel and project management). All OECD countries are eligible and IEA Bioenergy is trying to encourage the involvement of industry.

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Everybody needs to eat. Biofuels are only one of many factors in food prices and environmental impacts. Speaking at GrainWorld organized by the Canadian Wheat Board, Geoff Stone, talking about commodities, introduced the slide on Food Prices with "I can take the bus if gas goes up... but I still have to eat." He suggests key impacts on supply are government policies and weather. Key impacts on demand are "More meat less bread" and ethanol, demand for which is expected to increase worldwide.

For "Demand: More Meat Less bread Means... Bread costs more Dough($)" he provides estimates for feed grains needed to produce 1 kg of meat:

Some of the policies implemented by countries in response to higher food prices included:
World demand for fertilizers to increase yields is expected to increase from 169 million tonnes in 2010 to 187.9 million tonnes in 2014 to supply nitrogen, phosphate and potash. Fertilizer prices are expected to remain high.

GL notes that some are calling our modern era "Peak Everything". Every time a crop is harvested, soil nutrients are removed. Depending on the soil, increasingly high yields require fertilizer. Hugh Martin, Organic Crop Production Program Lead at the Ontario Ministry of Agriculture wrote recently that "We hear a lot about Peak Oil which is a very important topic but very little about Peak P. Phosphorous (P) fertilizers are made from rock phosphate but global reserves of phosphate are predicted by some to reach "Peak P" within the next 30-50 years. Globally, it is not sustainable to continue to use phosphorous in the way that we have during the past 50 years! ...Plants require three major nutrients. Nitrogen can be biologically obtained from the air and potassium mineral reserves are much larger. It will be phosphorous that will be limiting to our future ability to produce food. "

Paid subscribers see link to original documents and references here.


The OECD-FAO outlook for agriculture for the decade 2010-2019 identifies strong links between food crops and energy including oil prices and biofuel production. However, though there is no doubt that government policies related to biofuels affect food prices by increasing demand for crops, biofuel production by itself does not cause food insecurity. There is enough food in the world but biofuel policies add complexity to an already complex situation. The assessment assumes average weather conditions and long term productivity trends as well as continuation of existing policies and technologies but the past few years haven't been average. Agriculture has been affected by a number of shocks including:
Reduced policy supports for biofuels in some countries as well as other factors such as decreased demand due to high prices and some bumper crops are seen as helping to improve the supply of food commodities after the shocks.

Commodity supply and demand for the next decade are affected by:
Some trends for the decade 2010-2019 include:
Food Security
The world produces enough to feed all the population but more than one billion people are food insecure. Many of the world's food insecure are farmers. Biofuels impact food supply by related land use changes.

The recent food price hike was affected by
Some of the ways to improve food security include
Price and Production/consumption

In real prices, average crop prices are expected to rise in the period to 2019 relative to 1997-2006. Average wheat and coarse grain (includes barley, corn, oats, rye, and mixed grains) prices are projected to be nearly 15-40% higher. vegetable oils 40% higher, dairy 16-45% higher with butter raising most in price due to higher energy and vegetable oil prices. Corn prices are expected to increase faster due to demand for biofuels and feed sectors, which are both growing but at a slower rate than the previous period. World sugar prices to 2019 will also be above the average of the previous decade but less than the high reached at the end of 2009. For livestock products, average meat prices in real terms, other than for pork are expected to be higher. Pork is expected to be relatively stable because Brazil and China are producing more. When people in developing countries change from eating staple grains to meat, they are most likely to choose pork or poultry because these are cheaper.

The world production of wheat and coarse grains (includes barley, corn, oats, rye, and mixed grains) is projected to increase by 14% and 19% respectively to reach 746 MT and 1,311 Mo 2019 compared to 1997-2006. This is likely to meet world demand or be higher than demand for world consumption of grains for food, feed and industrial use.

For rice, stocks are expected to increase by 18% and world rice prices should be lower ending in 2019 but rice prices are still expected to be 1.9 times the price of wheat (compared to 2.7 times in 2009). World production is expected to reach 522 MT by 2019 compared to consumption of 521 MT. As consumers in China become more affluent, they eat less rice.

Demand for sugar including for biofuels is likely to raise prices and demand but not above the peaks of recent years. World sugar production is projected to increase to just over 200 Mt in 2019-20, an increase of 24%.

Mandates for biodiesel, use of protein meal for livestock, and demand for oilseed and oilseed products are expected to lead to expansion of vegetable oils but not at the rate of growth of the previous decade. Most of the expansion will be in Brazil, EU and Argentina with land transferred from other uses and new land entering production. The US will remain the major oilseed producer to 2011. Expansion is expected to be limited by the costs of expanding areas of land and environmental concerns.

Biofuel Markets

Biofuel markets are difficult to predict. They depend heavily on government incentives and mandates but other factors such as crude oil prices, changes in policy and development of second generation technologies are unknown factors. The mandates to use biofuels will increase demand for wheat, coarse grains, vegetable oils and sugar as feedstocks. The second generation biomass ethanol and biodiesel should develop later in the decade reaching 7% and 6% of global production with most of biofuels produced from agricultural commodities still by 2019. Brazil is expected to be the major exporter of ethanol by 2019. Trade in biodiesel only marginal with Argentina supplying more of the market in 2019.

The EU's Renewable Energy Directive (RED) calls for a 10% share of renewable energy in the transport fuel mix by 2020. Many developing countries have had renewable energy programs that have been put on hold due to the economic crisis.

Canada produced 1,018 million litres of ethanol in 2007-2009 and is expected to product 1,891 million litres in 2019. Domestic use in 2007-9 is estimated 1,603 million litres (3.4% by volume of gasoline type fuels) in 2007-09 compared to 2,609 million litres (5% by volume of gasoline type fuels) by 2019. Ethanol has lower energy value than gasoline so the share of energy provided by the same volume of ethanol is less than gasoline. In Canada, the mandate for ethanol use (5% by volume on average for on-road fuel) is seen as the primary driver for ethanol use. Once the E5 mandate has been fulfilled soon after 2010, ethanol production is not expected to increase much until 2016 when both provincial and federal supports are scheduled to end.

Canada imported 585 million litres of ethanol in 2007-2009 expected to rise to 718 million litres by 2019. By contrast, the US imported 2,031 million litres of ethanol in 2007 and is expected to import 10,878 million litres by 2019. The US ethanol use in 2007-09 was 6.3% by volume of gasoline type fuel and is expected to rise to 12.1% by 2019.

The global production of ethanol was 74,257 million litres in 2007-2009 and is expected to be 158 849 million litres by 2019. The top five producers in 2007-2009 were US (34,888 mill), Brazil (25,308 mill), EU27 (4,890 mill),  China (3,917 mill) and India (1,949 mill). Canada was sixth.

In 2007-2009, Canada produced 138 million litres and used 137 million litres of biodiesel (0.4% by volume of diesel type fuels) domestically. In the next decade, it is expected to produce 457 million litres by 2019 and use 785 million litres (2% by volume of diesel type fuels). Canada is expected to import 307 million litres by 2019, probably mostly from Brazil. By 2019, the US is expected to be importing 19 million litres compared to 1,033 million litres in 2007-2009. In the US, the Renewable Fuel Standard RFS2 mandate states that 3.8 billion litres of biodiesel to be used by 2012. With no additional increase in the mandate after that as the next mandates are for advanced biofuels, the demand is expected to be stable. Trade in biodiesel is expected to be low.

Global biodiesel production in 2007-2009 was estimated to be 15,170 million litres and by 2019 41,171 million litres. The top six producers of biodiesel for 2007-2009 were EU27 (8,041 mill), US (2,319 mill), Argentina (1,286 mill), Brazil (958 mill) and Australia tied with Malaysia (515 mill) The EU is expected to be the largest user of biodiesel reaching 24,400 mill by 2019. The share of biodiesel in diesel type fuels is to expected to rise to 8% on average by 2019 in the EU.

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Purdue University researchers estimated global land use changes and greenhouse gas emissions associated with the US corn ethanol mandate of up to 15 billion galls in the Renewable Fuel Standard using a model which includes consideration of the three major biofuels (corn ethanol, sugarcane ethanol, and biodiesel), pastures in the US and Brazil and Conservation Reserve Program lands, calculation for co-products such as distiller grains for ethanol and how to calculate the production on marginal lands. The model is a special version of the Global Trade Analysis Project (GTAP) model, which includes 87 world regions and 57 economic sectors plus biofuel sectors added for this study. Thousands of economic studies globally on trade, energy, climate change, and environmental policy issues have been done using different versions of the GTAP model. A key issue in land use change is the lost opportunity for land to sequester carbon which some researchers say is far larger than benefit, if any, in direct greenhouse gas emissions from biofuels made from annual crops.
There are many uncertainties with modelling land use change and the authors who are working with the Argonne National Laboratory on further refinements. There is a wide range in some of the measures from models first developed in 1999 while other results whether with the updated model or old one are more stable..The fraction of land use change that occurs in the US is between 24-34% while the rest occurs globally. Of that change to cropland, about 23%-33% is originally forest and 67%-77% is pasture. These are seen as relatively stable using earlier and later models. The amount of land needed to meet the mandate is between 0.13 to 0.22 hectares/1000 gallons which is a wide range. The grams of CO2 emissions per gallon of ethanol range from 1167 to 1676 grams, also a wide range. The total emissions per megajoule of energy of 7.2 g/MJ and 84.4 g/MJ is a small range; the direct ethanol emissions of ethanol are assumed to be a constant so only the land use emissions are added. While another analysis using an early version of the model concluded that emissions from land use changes were between 2 and 51 g/MJ, the authors estimate 14.5 g/MJ. Emissions from land use changes due to ethanol are not zero, it is not possible to measure the GHG emissions from land use changes with high precision yet.

Ethanol GHG emissions as a proportion of gasoline are 83.7 and 90.5%. Corn ethanol may or may not meet a 20 percent standard due to the uncertainty. There is the potential for reducing GHG emissions with better and more efficient farming practices and with improving ethanol production.

Some of the other issues that may need further consideration are:
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To a considerable extent the expansion of farm crops for biofuels has been as much about support for agricultural producers than about the environment. When the USDS released its monthly corn supply and demand report recent, it included numbers on how much of the corn was dedicated to ethanol. A coalition of 34 state governors have asked the Secretary of Agriculture Tom Vilsack to doctor the numbers. (GL: We'll apologize if proven that isn't what they aren't essentially asking for). The letter says that "uninformed, or even malicious, media attacks have distorted the facts." Upward pressure on prices of corn and other commodities are due, they say to "global weather disruptions, rising oil prices, commodity speculation, and rising incomes that drive increased demand for grains and meat proteins."

The coalition also rejects that idea those who say ethanol's contribution to higher food prices led to regime change in Egypt. The corn report is said to be misleading because it doesn't clarify that the demand is a gross measure which doesn't account for use of the starch portion of the corn kernel, "This overstates the use of corn for ethanol by as much as a factor of two or more, and fails to inform the public about what is truly happening in the food and supply chain."

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The Agri-Environmental Performance Index improved from 1981 to 2006 according to the third report in a series called Environmental Sustainability of Canadian Agriculture. As biofuels expand and intensify agriculture, it is important to know how such intensification impacts on the environment.

Of Canada's total land area of 909 million hectares, 67.6 m ha are farmland. Of that in 2006, 58% was cultivated land, 31% pastureland and 11% other land.

One of the big improvements for protecting Canadian soils is the trend towards better land management practices such as conservation or no-till, reduced use of summer fallow and increased forage and permanent cover crops. Larger areas of land are in Western Canada so changes towards no-till were the most significant factor in the improvement in indicators measuring soil quality, erosion and soil organic carbon. About 72% of Canadian cropland is under conservation or no-till. Soil salinisation and soil contamination by trace elements improved as well but bear watching especially in specific regions. Air quality had a slight improvement over the 25 years. Some indicators show decline such as water quality (mainly due to increased applications of nutrients as fertilizers, manures and pesticides). The shift to cropland from natural or semi-natural land cover and intensification led to a significant decline in national habitat capacity.

Agriculture in Canada from 1981 to 2006 increased in intensity with less pasture and idle land in Eastern Canada and less summer fallow in Western Canada. More oilseeds, pulses and forages replaced traditional cereal grains. Removal of government subsidies for transport of feed grains led to a major shift of livestock from Eastern Canada to Western Canada. More beneficial management practices including conserving wetlands, woodlands, rotational grazing are recommended to improve habitat capacity especially in regions showing serious decline.

GL notes that we have been reading in Ontario Farmer newspaper that farmers here in southern Ontario are becoming disillusioned with no-till. Weeds are becoming resistant not only to glyphosate but other pesticides due to widespread production of genetically modified crops which sometimes become weeds themselves, for example as volunteer BT corn crops up in the next crop (in cropping, volunteer means plants growing where they are not intended to grow). Here in Haldimand, we saw what looks like a near majority of fields plowed this fall and left fallow over the winter. More and more farmers are ploughing right into the road allowance after they removed every tree and bush which used to line the road, the trees which used to line low lying areas in the field and the hedgerows along the fence line. One farmer told us that it might be only a metre but it made a difference in revenue. The result is visible erosion as sediment flows into the ditches and a huge loss to habitat. It is also a loss of organic materials. Where trees have grown, the soil level is sometimes a foot higher than what is on the cropland. Some farmers are doing very little rotation. One nearby farmer grew nothing but soybeans for 10 years; soybeans leave very little residue on the soil surface even if the field is no-till. Ontario fields tend to be smaller than prairie fields but even so one cannot help but think that it is no wonder that bees are having trouble, With all these monocrops some of them wind-pollinated, bees have a long way to go to find something in bloom during much to the season.

Factors Affecting Future Productivity and Environmental Impacts


About 1 million hectares of soils on the Prairies have moderate to severe soil salinity. Surface and shallow ground waters can receive salt from drylands.

            Trace Elements

Trace elements TEs such as copper, selenium and zinc are essential for animals, humans and plants but other TEs are harmful and an excess of beneficial TEs are also harmful. There is a flux of TEs as some are lost as others are added. Some soils already exceed the guidelines set by the Canadian Council of Ministers of the Environment ccmc. TE additives are common in feed and because they are cheap, commonly added at the maximum level allowed. Excess is then excreted in the manure. Sewage sludge also contains TEs and if spread onto farmland increase the TE levels.

The Risk of Soil Contamination by Trace Elements measured six elements: arsenic, cadmium, copper, lead, selenium and zinc. There is limited data available on TE concentrations in farm products and in soil. The overall risk related to toxicity hasn't changed much overall in Canada between 1981 to 2006 but regionally effects should be researched. If current practices continue (use of fertilizer, feed supplements and biosolids), "there is potential for effects on crop productivity, market access and on human and animal health." Sandy soils under intensive livestock operations or crop production are most likely to be affected.

About 1% of agricultural land in Canada is thought to be at very high risk for toxic impacts. For specific provinces, as much as 16% of the farmland is in the very high risk category. The background concentrations of TEs, another measure, are highest where population and agriculture are closely associated ie in the Windsor to Quebec City corridor where biosolids are commonly applied and where many animals and high-input agriculture is practised. The potato growing area in the Maritimes and the area around Winnipeg where intensification of animal production is occurring are also high in background TEs. Biosolids are the biggest contributor but are applied on only a small part of the land base.

            Habitat Capacity

Between 1986 and 2006, the capacity of agricultural land in Canaada  to support wildlife as measured by "habitat capacity for breeding and feeding (HCbf)"  decreased. Only Manitoba and Saskatchewan improved over the 20 years. In  Most agricultural land has low habitat capacity (46.5%) and very low capacity (40.6%)  Between 1986 and 2006, HCbf remained constant on 75% of agricultural land, declined significantly on 14% and increased on 11%.  Different provinces had more dramatic changes.
            Water Quality

Since 1981, more land area for crops, no or low till practices which substitute pesticides for tillage, and changes to types of crops led to an increase in pesticide use in 2006 compared to 1981.About 86% of farmland was still at low to very low risk of contamination by pesticides.

Eilers, W., R. MacKay, L. Graham and A. Lefebvre (eds). 2010. Environmental Sustainability of Canadian Agriculture: Agri-Environmental Indicator Report Series — Report #3. Ottawa, Ontario: Agriculture and Agri-Food Canada, 2010.


Agrimarkets Analyst Kevin Grier, of the George Morris Centre in Guelph (Ontario) which researches food and agri-business issues with industry funding, has blamed US policies for ethanol for runaway corn prices and higher feed prices for livestock. He is quoted as saying, "First and foremost the direction of the prices is driven higher by ethanol.

In 2011 it's conceivable that ethanol will burn up more of the corn crop than will be consumed by livestock and poultry and it's a case of ethanol becoming a run away train.

I don't think anybody anticipated that we'd get to a situation where ethanol uses up more corn than the livestock industry so in and of itself that is the single reason why we've got this out of control grain price situation.

Our crops in 2010 were near record large so we need to continue to have record large crops in order to feed the ethanol beast which is again fuelled by subsidies, tariffs and mandates.

It's an extraordinarily artificial pricing situation but the reality of it is it's driving livestock producers out of business."

The Grain Farmers of Ontario expressed offense at his "demonizing ethanol." Don Kenny, chair of the GFO said all the commodities are trading at near record high prices and singling out corn is just pitting one commodity against another. It used to be a struggle for farmers making only $3 a bushel compared to current prices around $7 a bushel. He said that while Grier suggests the byproducts are near worthless, Dried Distillers' Grains DDGS sell for $262 per tonne. GL notes that in life cycle assessment the environmental impacts of byproducts with a market are subtracted from those of the biofuel.

According to Statistics Canada, Ontario is a major player in the ethanol market in Canada: "In 2009, 67% of ethanol produced in Canada was made from corn (all in Eastern Canada), and 31% from wheat (all in Western Canada). Ontario is the largest corn producing province in Canada, and 55% of Canadian ethanol capacity is in Ontario. In the 2008/09 growing season to Aug 31, 10.6 MT (million tonnes) corn was produced in Canada and 1.9 MT imported from the US for a total of 12.5 MT...7.6 MT were used for feed and 4.1 MT were used for ethanol and domestic food."

Gallon Environment Letter has not researched this issue of ethanol demand forcing higher feed prices in depth but we are inclined to side with the Grain Farmers of Ontario. Grain prices have been too low for too long and the work of the OECD and others suggests that biofuels are not the major cause of food price spikes in developing countries. For Canada, getting away from our cheap food policy and moving to food pricing that means a reasonable wage for farmers would seem to be a good idea. By its mandate, the George Morris Centre is pro-industry, not necessarily pro-environment, pro-farmer, or pro-consumer.

Paid subscribers see link to original documents and references here.


In its 2010 report card on the biofuels industry, the Canadian Renewable Fuels Association says the questions about the sustainability of biofuels are "popular myths". Examples are
Canadian Renewable Fuels Association. Growing Beyond Oil: Delivering Our Energy Future: A Report Card on The Canadian Renewable Fuels Industry. Ottawa, Ontario: November 2010.


Both the EU and California have regulations including sustainability criteria for renewable fuels. The EU has included similar criteria for their Fuel Quality Directive which is creating a stir because it will potentially affect the status of oil from the oilsands.

In California, changes are being made to the Low Carbon Fuel Standard regulation. New carbon intensity lookup tables are being developed. Fuel providers can also make submissions for approval to add to the table. Regulated transportation fuels have to use lifecycle analysis. While the federal regulation exempts existing and planned corn ethanol from GHG requirement, the LCFS covers biofuels and non-biofuels with some limited exceptions. The State document says its program is more innovative because it recognizes compressed natural gas, electricity and hydrogen in providing low carbon fuels. Fuels with a carbon intensity lower than the standard will receive a credit and those with a CI higher will receive a debit for that year. Credits and debits are used to achieve carbon intensity reduction.

Carbon Intensity of Various Fuels

The carbon intensity value includes direct emissions and where applicable a land-use change element and is reported in g of CO2eq/MJ. Examples are Gasoline has direct emissions of 95.86 and no land use for a total of 95.86. Ethanol from corn from the Midwest with one process is 69.40 direct and 30 land use for a total of 99.40 with some other processes even higher. There are pages of rows for corn ethanol, all have a land use change of 30 but some have as low as 43.2 for direct emissions.

For Brazilian sugarcane, land use changes are 46. One fo the lowest direct emissions was 12.40 for an average production process, mechanized harvesting and electricity co-product credit. No US ethanol is as low as 58.4 g of CO2eq/MJ.

Landfill gas (bio-methane) converted to LNG using liquefaction with 90% efficiency had direct emissions of 15.56 and no land use change.

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Subject: Response to Your Article: "Why Is the Minister Misquoting Biodiesel Experts?" Gl V15 N11

Good day,

In response to your article "Why is the Minister misquoting biodiesel experts?", I would like to correct the facts.

The July 1 start date for the 2 per cent biodiesel requirement is a proposed date. A 60-day comment period is provided between the proposed regulation in Canada Gazette, Part I and a final regulation in Canada Gazette, Part II to give stakeholders the opportunity to present their views to the Government before this amendment is finalized.
There will also be an extended initial compliance period of 18 months so that industry will have an extended period of time in which to fulfill the blending requirement. This, combined with other provisions currently in the regulations, will provide flexibility for companies in meeting the requirement.
When fully implemented, the Strategy's two regulatory requirements combined with provincial regulations will ensure a total volume of renewable fuel that will reduce annual greenhouse gas emissions by up to four megatonnes - about the equivalent of taking one million vehicles off the road. This initiative supports our commitment to reduce Canada's total greenhouse gas emissions by 17 per cent from 2005 levels by 2020.

Henry Lau, Spokesperson. Ministerial Communications Services, Environment Canada


The Canadian Japanese Cultural Centre awarded Canadian environmental icon and guru the 2011 Sakura Award. The presentation will be made at the Third Annual Sakura Ball on April 11, 2011. He is recognized for a long list of achievements listed in the award which is given to individuals for "exceptional contributions to the promotion and exchange of Japanese culture and enhancing awareness of Nikkei heritage within Canada and abroad."

As part of the events, the JCCC presented the 2010 film about his life, Force of Nature: The David Suzuki Movie on March 24 with film director Sturla Gunnarsson. The film has also been on television recently. As someone commented to one of GL's associates, it's the story not only of Suzuki but, ranging over 70 years, also a history of the times. with Suzuki fitting right into the hippy era. Lots of the movie features what Suzuki does best, talking about connection to nature, the threat to the planet, calling for action. and explaining the complexities of natural science. Definitely not an action movie but if you care about the environment, definitely worth seeing.

Canadian Japanese Cultural Centre. Third Annual Sakura Ball April 11, 2011.


In recent years there has been substantial pressure to make good use of waste materials. Some of these programs have involved use of coal ash (known in this report as Coal Combustion Residuals or CCRs). After all, would it not be better to use coal ash as a component of drywall (also known as wallboard or plasterboard), for filling old quarries, as a component of concrete, as a road base, or for building berms which provide a sound barrier along highways than to put it in a landfill.

Not so fast, states the Inspector General of the United States' Environmental Protection Agency in a recent report. Some of the things that have been done with coal ash have not been properly evaluated and may not be such a good idea.

The IG states that in some cases the EPA had insufficient information to evaluate the environmental impacts of these 'beneficial uses' of coal ash. He states that the EPA needs to 'define and implement risk evaluation practices to determine the safety of the CCR beneficial uses EPA promotes' and to determine if further action is warranted to address historical structural fill applications that have used ash. The EPA, in its response, indicates that the Inspector General did not have access to all of the information about the environmental reviews conducted by the EPA. While, for lack of information, GL cannot take sides, we find it difficult to support an argument that a governmental body did not communicate the activities and results of its own research to its own Inspector General.

In the year 2000 EPA decided that CCRs do not warrant regulation as hazardous waste and that 'beneficial uses' of CCRs, other than minefills, pose no significant risk and no additional national regulations are needed. Coal ash is known to contain metals such as arsenic, selenium, cadmium, lead, and mercury, in low concentrations. These metals can migrate into groundwater and find their way into drinking water wells. Contaminated dust can also adversely impact vegetation. In 2001, in partnership with industry, the EPA launched a program with the objective "By 2011, [to] increase the use of coal combustion ash to 50 percent from 32 percent in 2001."
The IG's findings are stated very explicitly:
As previously stated, EPA does not concur with the IG's conclusions. Readers are referred to the following link for EPA's point of view.
Paid subscribers see link to original documents and references here.
While trolling the web GL's editor found an article on the United Press International wire entitled "Spring means melting snow -- and pollution". By the time the article had bounced around a few websites and blogs it had acquired the title 'The dark side of spring? Pollution in our melting snow'.
The article contains quotes from Torsten Meyer, a University of Toronto post-doctoral fellow in environmental chemistry. In one he was reported to have said "During the winter months, contaminants accumulate in the snow. When the snow melts, these chemicals are released into the environment at high concentrations." Given that snow has no ability to magnify the total quantity of pollutants, GL decided to investigate further.
The original research, published in the journal Water Research, looks to be solid. The research, conducted under real conditions at Toronto's Highland Creek, shows that organic substances trapped in the snow pack may not be released at a uniform rate as the snow melts but may be released in concentrated pulses, some at an early stage of the melt and others at the end of melting. As a result of these release pulses, the concentration of PAHs, one of the more common industrial and vehicle pollutants, temporarily increased in the river by a factor of 3, about the same as happens during heavy rain events during the summer months.
The research has useful implications for measurement of water quality and for understanding the temporal accumulation of contaminants in river and lake sediments but we have to take some issue with the conclusions of the article. One version of the article states that "According to Meyer, cities and towns should be very careful to select well-contained sites to protect against that early flush of pollutants.".
GL's view is that having municipalities spending lots of time and money to select well-contained sites to protect against the early flush of pollutants when the snow melts is a pollution control approach which does little to address the real problem. Winter snow is a problem not just for PAHs but also for road salt, likely far more toxic to aquatic organisms than the PAHs. The snow does not magnify the total concentration of PAHs which go into surface waters, though we acknowledge that snow dumps may somewhat localize the concentration of PAHs in surface waters. Whether or not a three times concentration of PAHs will prove especially harmful to aquatic organisms in the spring is, in GL's opinion, an open question but if the 3x concentration also comes from heavy rain events, which seems likely as roads and paved areas are flushed down, then worrying about snow dumps may be only one of many problems with toxic substances getting into our rivers and lakes.
While not wanting to oppose better containment of snow dumps, GL suggests that better containment of snow dumps may be one of the lower priority solutions. Maybe we should treat surface runoff and snow melt before discharging it to rivers and lakes, though we acknowledge this would be a very expensive solution. The real solution rests with reducing emissions of PAHs to the environment. Then we would not have to worry so much about the contaminants in the collected snow. And while writing about winter snow and the environment we urge you to avoid using road salt on your roads, drives and paths. It has been determined by Environment Canada and Health Canada that, in sufficient concentrations, road salts pose a risk to plants, animals and the aquatic environment.
Paid subscribers see link to original documents and references here.
A recent newsletter for educators from ECO Canada touted a flying car as an environmental technology for 2011. ECO Canada is the 18 year old non-profit that used to have the more descriptive but much longer name Canadian Council for Human Resources in the Environment Industry.
Much as ECO Canada's editors might be intrigued by the flying car concept, as was GL's editor when a kid, it is with regret we have to inform them that it takes a real stretch of imagination to consider a flying car as an environmental technology. More likely, if it ever comes to market on a large scale, it could be the technology that puts a very big nail in the coffin of human existence on earth.
There are basic laws of physics that mean that it takes more energy to fly than it does to travel around on wheels. There is some debate about large aircraft, for example flying in a plane with 239 other passengers over a reasonably long distance MAY use less fuel and have a lower environmental impact than driving 240 cars over the same route, but the Terrafugia Transition, the flying car about which ECO Canada was writing, is not a large jet. It is a compact 2-passenger vehicle that converts to a plane, requires a runway, not a road, for takeoff, weighs 970 lbs empty, and burns 11 litres per 100 km while flying. On the road its rating is claimed to be 6.7l/100km. A Smart fortwo car, which appears to have roughly the same interior space as a Terrafugia Transition, has a highway fuel consumption rating of 3.7 litres per 100km. There are lots of cars available which do better than 11 liters per 100km.
ECO Canada does a lot of good work so we have to assume that touting flying cars as an environmental technology was a mistake. We might also note that the flying car was apparently developed by a group of MIT-trained aeronautical engineers but the car is being commercialized by a private company with no connection to the Massachusetts Institute of Technology.
Flying Cars from MIT. The ECO Explorer.
Terrafugia Inc.
Tea Party endorsed Representative Morgan Griffith recently circulated a newsletter in which he stated "a new ruling by the Environmental Protection Agency would force dairy farmers to comply with the Spill Prevention, Control and Countermeasure Program when dealing with spills of milk – the same regulations oil and natural gas producers must follow."
In fact, on a request from the dairy industry, the EPA has been working since 2009 on a regulation to exempt milk tankers and milk storage from the SPCC rule.
What Morgan Griffith reported to his constituents and, through the media, to the US public appears to be the exact opposite of the truth. But then, if you are having a Tea Party, who would not want to make a fuss over spilt milk?
Spill Prevention, Control, and Countermeasure (SPCC) Rule and Milk. U.S. Environmental Protection Agency.
Congressman Griffith's E-Newsletter - February 11, 2011
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