Guidance to providing your input to AAFC’s Sustainable Agriculture Strategy

The NFU has created a guideline for how you might want to respond to Agriculture and Agri-Food Canada’s (AAFC) questionnaire towards developing a 25-year Sustainable Agriculture Strategy. Use this as inspiration—you are encouraged to tailor these responses and use your own words.

Deadline is March 31st 2023. Your voice matters. Add yours today!


Guidance to providing your input to AAFC’s Sustainable Agriculture Strategy

Briefly: It is important that you please provide your input to AAFC’s Sustainable Agriculture Strategy (SAS) consultation. Please go online and fill in the questionnaire, or send in an email. There is a 29-page AAFC SAS Discussion Document. In drafting your input, focus less on the SAS goals (vague) and more on outcomes and targets. Urge AAFC toward ambitious outcomes and targets. Deadline is March 31st. Email address and questionnaire link below. Agriculture and Agri-Food Canada (AAFC) has initiated a process to develop a 25-year Sustainable Agriculture Strategy (SAS). On two pages, this NFU document tells you what you need to know about the SAS.

Here is a link to AAFC’s SAS site, including a link to their 29-page Discussion Document.

There is a consultation process that ends March 31st. You can provide written input three ways:

  1. Fill out their questionnaire (you can start filling it in, save, and resume later): and/or
  2. Submit your answers to the Discussion Document questions (which are the same as those in the online questionnaire) via email to: and/or
  3. Submit a more general letter or report outlining your thoughts on agriculture system sustainability via email to: (You may want to do this in addition to, but not instead of, filling out the questionnaire or answering the Discussion Doc questions via email, because AAFC’s questions are sub-optimum.)

Again, the questions in the Discussion Document and in the online questionnaire are the same. So you have the option of filling in the questionnaire or setting out your answers in an email.

Below are some ideas you may want to consider in drafting your input to AAFC re their SAS. You are encouraged to add and subtract, to tailor this to your own thinking, and to use your own words. Before you begin, perhaps read the 29-page SAS Discussion Document: e-strategy/document

The SAS Discussion Document and the online questionnaire divides the questions into three issue sections. Below, AAFC background text is in bold black. AAFC questions are in red. NFU suggestions are in italic green.

In general, as you answer AAFC’s SAS questions, consider making these foundational points:

A. We need true, authentic sustainability, not half-measures or sustainability-as-a-marketing-tool.
B. Achieving true, authentic sustainability will be much harder than most imagine, as most human systems (incl. mining, manufacturing, consumption, housing, heating, transportation, energy) are far from sustainable and probably getting worse, and the same is true for food production systems.
C. Because we’re far from sustainability, we need bold, ambitious, transformative changes; tweaks to business-as-usual, incremental changes, and techno-add-ons will fail.
D. We need a systems approach—a holistic framework. Agriculture is a complex interconnected system and transformative change needs to take this into account.
E. Farm incomes and financial security must be forefront. We need changes that reduce environmental harms but that also increase margins, reduce debt, decrease dependence on purchased inputs, stop the expulsion of farmers, and reverse farmland concentration.
F. Low-input approaches are key. Many of the environmental harms (e.g., GHGs, toxicity, resource depletion, etc.) from agriculture are a direct function of the quantity of farm inputs we push in. I.e., low-emission systems will be low-input systems.
G. Endless growth cannot be sustained. Most agricultural metrics (e.g., grain and oilseed tonnage, pork and chicken prod’n, fertilizer use, pesticide use) are doubling and redoubling on 20- to 40-year timeframes. If input use and output are continuously driven upward, sustainability cannot improve.
H. The top priority is that we stop developing new fossil fuel projects (e.g., Bay du Nord) and that we rapidly reduce fossil fuel combustion to zero well before 2050.
I. Avoid technologies that are not in farmers’ interests, such as gene editing. Also, ensure that farmers rights to their seeds are expanded, not reduced.
J. We oppose corporate-centered “market-based mechanisms” such as carbon offsets and emissions trading that enable a continuation of business-as-usual while giving false hope.
K. Diversify production approaches and set acreage targets for more positive alternatives, such as low-input, regenerative, agroecological, and organic production.
L. Adaptation is not a one-and-done process, rather, adaptation will be ongoing for this entire century, and beyond, as the climate continues to respond to GHG emissions; indeed, the pace of dangerous climate change will accelerate due to human activity, so adaptation measures must be intensified as we move through the coming decades.
M. Control within the system is an ignored factor. Corporate control needs to be restrained and concentration reduced. Farmers need more control in the system via collective marketing agencies. Governments need to take a more central role to counter “market forces” pushing for more output and more input use and, hence, higher emissions and lower sustainability. A Sustainable Agriculture Strategy will be ineffective paper unless governments act to counter corporate power.
N. Integrate crucial considerations of the public good; the value of common lands; reconciliation with, and justice for, the Indigenous peoples who are the original (and often current) owners of this land; and a renewed and much more ambitious commitment to democracy, equity, inclusion, and social justice.
O. We need a multiplication of effort and speed—near-wartime levels of ambition and action as we struggle to blunt the massively damaging impacts of accelerating climate change. We are moving far too slow, we are losing, we risk losing everything, we must act faster. We need a government-led mobilization for food-system transformation.
P. To accomplish the above, AAFC needs expanded capacities. We need new agencies. We propose the creation of a Canadian Farm Resilience Agency (CFRA) (details: ) A CFRA could deploy public-servant agrologists focused on input optimization and emissions reduction, supply free soil testing, collect and share needed data, lead adaptation, and create a network of demonstration farms where sustainable, low-emission practices can be refined and showcased.

In general, focus on suggesting clear, ambitious outcomes and targets for AAFC and their SAS. (The SAS distinguishes between “goals,” “outcomes,” and “targets,” and the “goals” are vague and getting vaguer.) Think about four to six key outcomes you’d like to see (e.g., the end of wetland drainage; or a rapid increase in the area of trees on marginal farmlands) and think about targets (e.g., a 20% reduction in ag GHG emissions by 2030; or net-zero ag by 2050 with interim targets every five years to ensure continual progress).

Here are the SAS questions, and some ideas regarding how you might answer them.

Issue 1: What do we want to achieve through a Sustainable Agriculture Strategy? 

Proposed Goals for a Sustainable Agriculture Strategy:

  1. The agriculture sector is resilient to short and long-term climate impacts while growing productive capacity, and has adapted to changing contexts due to climate change
  2. Environmental performance is improved in Canada’s agriculture sector, contributing to the environmental, economic, and social benefit of all Canadians.
  3. The agriculture sector plays an important role in contributing to Canada’s national 2030 GHG emission reduction and net-zero by 2050 targets while remaining competitive and supporting farmers.
  4. A more comprehensive and integrated approach is taken in addressing agri-environmental issues in the agriculture sector, across policy, programming, and partners in the value chain.
  5. Canada has addressed data gaps and improved capacity to measure, report on, and track the environmental performance of the agriculture and agri-food sector.

Specific outcomes would be associated with each goal — measurable changes that occur as a result of collective action across existing and new policies, programs, and initiatives within the timeframe of the strategy. Outcomes for a Sustainable Agriculture Strategy that could be considered include:

  • production is more resilient to climate change
  • GHG emissions in the agriculture sector are reduced  
  • the sector has increased capacity for carbon sequestration
  • use of energy efficient and clean technologies on farms is increased
  • biodiversity-rich landscape features are maintained and/or improved on agricultural lands (for example wetlands, grasslands, and treed areas)
  • ecological services are measured, maintained, and sustainable
  • a more comprehensive approach to water management is taken in agriculture

Discussion Questions

Which of the proposed goals for a Sustainable Agriculture Strategy do you agree with most? What would you add or change?

Again, the five goals above are vague (and becoming more so), so you may want to focus most on the outcomes and targets in the following questions. Feel free to highlight one goal over another if you see one as most important. Alternatively, you may want to say that we need a holistic, systems approach, therefore significant progress is needed toward all goals equally. If you want to suggest alternative wording for a goal, go ahead, but, again, note that many of the specifics will be captured in the outcomes and targets, below, and not in the goals themselves.

➣What should a Sustainable Agriculture Strategy aim to achieve in the agriculture sector in terms of:

This section is key. Here, we can get specific and push for rapid, transformative changes.

  • Climate change mitigation (at the SAS table, this means emissions reduction)

Consider suggesting some of these outcomes or similar ones (some are not compatible with others, so choose):

  1. Emissions from fertilizer use (absolute, not intensity based) are cut by half, or more, by 2050
  2. Agricultural emissions are 20% lower by 2030 and 40% lower by 2050 (all in absolute terms)
  3. Agricultural emissions are 20% lower by 2030 and the sector is net-zero by 2050, i.e., emissions equal sequestration. [The NFU, FCS, other orgs, alongside scientists and economists will undertake ambitious research over coming months to detail possible paths and scenarios for net-zero agriculture in Canada]
  4. All new agricultural machinery sold is zero-emission by 2040, and we have taken parallel steps to ensure that our electricity generation and distribution systems supply low-emission renewable energy to farms
  5. Farm building retrofits cut energy use and emissions by half by 2030 (with changes spurred by needed financing and incentive programs)
  6. Soil carbon sequestration is increased 50% by 2030
  7. Tree planting, re-grassing, and wetlands restoration on marginal farmland increases landscape-level sequestration
  • Adaptation

Consider suggesting some of these outcomes or similar ones (not all are compatible with all others):

8. Very ambitious measures to maximize the rate of soil organic matter gain are in place by 2030, leading to increases in sequestration rates of several percent per year
9. In addition to agronomic resilience, we maximize financial resilience by focusing on increasing margins and reducing debt; reducing input dependance can help
10. Support for mixed farms, more complex rotations, and other practices to minimize risk
11. Adaptation cannot be limited to investments in productive acres alone. Resilient landscapes make resilient farms and ranches and the protection and restoration of wetlands; grasslands; treed areas, hedgerows, and fencerows; and other ecologically sensitive areas must also be a priority.

  • Biodiversity

Consider suggesting some of these outcomes or similar ones:

12. The destruction of wetlands is stopped then reversed, with number and area increasing
13. Tree removal is stopped then reversed with very significant gains in treed area by 2030
14. The destruction of grassland is stopped and grassland area is increased
15. Insecticide and herbicide tonnage are decreased by 10% by 2030 (and 20% by 2040)
16. Biodiversity, on a broad set of metrics (e.g., insects, birds, plants, animals, soil biota, etc.), is increasing by the 2030s
17. Both in-field biodiversity (e.g., more complex rotations, more legumes, intercropping) and whole-landscape biodiversity (outside of fields, too) are increasing
18. Existing forests are protected and the agricultural land area is not allowed to extend northward as climate warming advances

  • Water

Consider suggesting some of these outcomes or similar ones:

19. Fertilizer run-off, soil erosion, and other losses to rivers and lakes are reduced and continue a downward trend 20. Manure run-off and other losses to rivers and lakes is reduced and continue a downward trend
21. Pesticide run-off and other losses to rivers and lakes is reduced and continue a downward trend
22. Wetlands destruction, drainage, and diversions are stopped and wetlands area is increasing
23. Biodiversity in on-farm wetlands is increasing
24. Nitrate leaching to groundwater is decreased
25. We understand that the damage done by irrigation megaprojects is antithetical to the goals of sustainability and so do not pursue them

  • Soil health

Consider suggesting some of these outcomes or similar ones:

26. Take a holistic, ecological-based, multi-faceted approach to soil health, not just carbon or primary nutrients: N, P, and K
27. Soil organic matter (aka soil carbon) gain rates are maximized via very rapid and ambitious adoption of all BMPs including reduced tillage, cover crops, enhanced rotations, etc.
28. A more diverse suite of approaches is fostered, including regenerative, organic, agroecological, and low-input systems, and acreage targets are created for these approaches
29. Regenerative practices (keep the soil covered, keep green plants growing and living roots in the soil, diversify crops, intercropping, etc.) are proliferated broadly and aggressively adopted
30. Because increases in pasture and grasslands are important ways to keep the soil covered, rotational grazing and related BMPs are maximized.
31. We need comprehensive efficacy testing and reporting for fertilizer alternatives—biologicals and other yield-supporting and soil-building supplements. Government testing can help farmers know what works and what doesn’t and help reduce fertilizer use and emissions

How can a Sustainable Agriculture Strategy support an environmentally, socially, and economically sustainable agriculture sector?

32. A broad, open-ended question. Answer as briefly or in depth as you like. Consider mentioning farmers’ margins (which can improve when they are less input dependent) and debt loads (at a record-high today of about $1,000 per acre). Perhaps mention rural communities and intergenerational transfer. The list is endless. Key is that we do not erode the financial conditions as we move toward sustainability, but more than that, many of the measures to improve environmental sustainability (improved soils, lower input use, better water management) can also increase financial sustainability. There are some triple wins: increasing financial, social, and environmental sustainability.
33. Again, AAFC capacity must be dramatically increased; we need a CFRA and public-interest, public-sector extension and research as part of the Strategy.

Issue 2: Approaches to overcome barriers and advance environmental outcomes in the sector

…the following points were raised most frequently by participants as barriers to adopting beneficial management practices and technologies that support improved environment and climate outcomes:

  • uncertainty about economic benefits, costs, and risks of yield changes when adopting particular practices/technologies
  • lack of recognition of early adopters of environment and climate-smart practices
  • insufficient knowledge, training, or access to technical expertise/advice to adopt a specific practice/technology
  • cost of adoption and maintenance of environment or climate-smart practice/technology
  • time required to implement and sustain a particular practice/technology
  • insufficient availability of labour or labour with the right skills (for example for data-intensive production, precision agriculture)
  • lack of knowledge and tools required to measure outcomes, such as GHG emissions, or meet reporting requirements for assurance standards
  • rising input and output costs
  • speed of regulatory processes
  • lack of access to rural broadband connectivity
  • generational and cultural differences in farm management approaches

… The following are approaches that could be considered under a Sustainable Agriculture Strategy to help advance the strategy’s goals and outcomes and overcome existing barriers. …

  • knowledge transfer and extension — activities that increase farmers’ access to the information, advice, and training they need to effectively implement practices on their farm that advance environment and climate outcomes. For example, agricultural extension, demonstration sites, regional climate risk assessments, on-farm GHG calculators, life cycle analyses.
  • supporting advancements in clean technology and digital adoption — approaches that invest in and further incentivize the development, demonstration, commercialization and adoption of clean technology in the sector. For example, zero-emission on-farm equipment or machinery, precision agriculture, artificial intelligence, and innovations that enable the use of alternative and bioenergy.
  • financial incentives for adoption of on-farm beneficial management practices — direct financial incentives to farmers that, for example, cover costs required to establish and maintain on-farm practices that support climate and environment outcomes or support the provision of ecological goods and services.
  • economic instruments — tools and practices that use markets, price, and other financial incentives and economic variables to reduce or eliminate unintended environmental impacts. For example, tax incentives, lower interest rates on loans for farmers implementing climate-smart/environmentally-smart practices, leveraging business risk management programming to incentivize practices and eliminate disincentives for action.
  • market-based opportunities — market-based benefits that incentivize the adoption of environmentally sustainable practices. For example, industry-led sustainable sourcing and certification schemes, voluntary or regulated carbon offset markets.
  • regulations — amending existing or establishing new regulations that could establish performance standards and/or mandate or prohibit use of a specific agricultural practice to efficiently and significantly scale up the adoption of practices or technologies that currently have low levels of adoption. Climate-friendly new practices, technologies and/or products may also require regulatory approval, along with approaches to address any potential hurdles and prolonged timelines.
  • science and research — filling existing knowledge gaps, improving measurement and monitoring, and developing new varieties of crops and livestock to help advance environment and climate outcomes in the sector.
  • solutions along the supply chain — supporting solutions along the supply chain that ultimately have a positive impact on on-farm environmental performance, as well as other environmental benefits along the supply chain. For example, 7advancing the growth of the bioeconomy sector, finding innovative solutions to reducing food loss and waste, and advancing circularity in the sector.
  • working with Indigenous Partners — collaborating with Indigenous partners on Indigenous specific policy and programming that supports sustainability in Indigenous agriculture and food systems, including on actions that strengthen Indigenous-led food systems through environmental benefits.

Discussion Questions

What success stories can you share about approaches to improve environment and climate outcomes in the sector? In what way have those approaches impacted yields or costs?

34. Add what you like here. Perhaps share what you’re doing on your farm. But underscore that, in general, the success stories are the exceptions, and most of the trendlines (e.g., fert tonnage, wetland area, emissions) continue to move in the wrong direction.

What suggestions do you have for additional approaches that could be part of a Sustainable Agriculture Strategy to:

    • Support environment and climate outcomes in the agriculture sector in general?

35. Here is the place to underscore the need for true, authentic sustainability, not half-measures or sustainability-as-a-marketing-tool. We can also underscore the need for transformative change and a holistic, systems approach. We can wave them away from vague, in-the-future techno-solutionism, noting that tweaks to business-as-usual, incremental changes, and technological add-ons will fail to bend the curves toward sustainability. We can also stress that low-input approaches are key. Many of agriculture’s environmental harms (e.g., GHGs, toxicity, resource depletion, etc.) are a direct function of the quantity of farm inputs we push in. I.e., low-emission systems will be low-input systems.
36. We need government-led transformative change and, therefore, dramatically increased capacity at AAFC, including a CFRA.
37. Endless growth counters sustainability. Most agricultural metrics (e.g., grain and oilseed output tonnage, pork and chicken prod’n, fertilizer use, pesticide use, etc.) are doubling and redoubling on 20- to 40-year timeframes. If input use and output are continuously driven upward, sustainability cannot improve and will, in fact, diminish. An agricultural sector with double the output and double the input use will have more adverse impacts. And we are on track to double the size of the sector in the coming 30 to 40 years. 

    • Support the agriculture sector in reaching net-zero by 2050?

38. Key is government and AAFC capacity. We need new institutions to provide the agronomic support farmers need. One proposal is a Canadian Farm Resilience Agency, CFRA. For background on the NFU’s CFRA proposal, see the two-pager here:
39. Maximize progress on expanding availability of clean, near-zero-emission electricity to support decarbonization of machinery and buildings.

Given the pace of change needed, in which areas could regulatory approaches or changes to existing ones be used to accelerate environment and climate action?

40. Again, this is a place to underscore the need for AAFC capacity: extension agrologists, demonstration farms, free soil testing, research into low-input ag, and a CFRA.
41. In general, regulations should not yet be a priority tool. Key is to give farmers options and to support adoption via public-servant extension agrologists, etc. Once options are widely available and farmers have adequate support, regulations may then be appropriate.
42. Examples of regulations needed now, however, include restrictions on wetlands destruction, elimination of foreign ownership of farmland, and protections for trees.

What type of research should be prioritized to advance environment and climate outcomes in the sector? Two kinds of answers may be warranted here:

43. Research and development are needed toward the following goals:

i. Widespread availability of non-fossil-fuelled, near-zero-emission agricultural machinery
ii.Low-input production systems that maintain yields while minimizing inputs
iii. Alternatives to purchased inputs, including circular flows of nutrients, biological nitrogen fixation, integrated pest management, etc.
iv. Low-emission grazing systems as alternatives to grain feeding & finishing
v. Zero-emission fertilizer prod’n (zero-emission energy and carbon capture)
vi. Strategies for cover cropping on the dry Prairies (e.g., time-release seeds)
vii. Perennial cereals
viii.Additional nitrogen fixing crops or abilities

44. But research and development is not a panacea. Too often, when faced with the challenges of the climate crisis, industry and government leaders default to vague talk of future technologies. To a very significant extent, the 2023-2050 emissions reductions will be accomplished by existing, broadly available technologies. We can make ambitious progress now; we need not wait on research or new innovations.

Issue 3: Targets and data on environmental performance

Acquiring timely and complete data is essential to understand where practices, programs, or policies are working and where more attention is needed. …

What kind of data are most important for measuring environmental and climate outcomes in the sector?

45. Go ahead and make long lists if you like. We need additional data collection on virtually every front: adoption rates of on-farm beneficial management practices (BMPs), water testing, energy use, emissions, etc. But we may want to consider that the government (e.g., Environment and Climate Change Canada, ECCC, knows what needs to be collected, but they lack the will/mandate/funds to undertake such collection. The government doesn’t really need help in identifying data gaps, they need to get busy and fill the gaps they already know well.
46. Make the point that data collection needs to be done by governments, not corporations. The latter are terrible at data sharing. We’ve heard government officials lament at how much data Deere has (as a result of its Big Data platform) and how that data is inaccessible for public-interest purposes.

What suggestions do you have for improving how environmental data is collected and shared in the sector?

47. Expanded AAFC or ECCC capacity is needed. There must be a federal presence in the countryside. Tools such as the Environmental Farm Plan (EFP) could be updated biannually to provide needed data. A CFRA could be a hub for data collection and sharing.
48. EFPs could be important ways of collecting data and acting upon it to spur action.

What qualitative or quantitative targets do you feel would be realistic, ambitious, and measurable to generate the most action in the following:

This is a key question, and should engage your time and thoughts. See above (e.g., answers 1-7) for some numbers. There are many possible targets. Some are suggested here. In general, make your suggested targets ambitious, specific, and rapid.

    • Reducing GHG emissions or storing carbon

49. See 1-7, above.
50. Net-zero emission agriculture by 2050, with intermediate goals to ensure continual movement in the right direction, e.g., 20% reduction in absolute emissions by 2030. [The NFU, FCS, other orgs, alongside scientists and economists will undertake ambitious research over coming months to detail possible paths and scenarios for net-zero agriculture in Canada]
51. To attain net-zero by 2050, attempt to achieve a 10% increase in cropland and grazing land soil carbon sequestration tonnage every 5 years.
52. 50% absolute reduction in fertilizer-related emissions by 2050 (building on ECCC/AAFC target of 30% reduction by 2030)
53. 100% reduction in emissions from new machinery sold in 2040
54. 50% reduction in emissions from farm buildings by 2030 (driven by incentive and financing programs)
55. 0% rate of wetlands rate loss by 2030
56. 10% increase in treed area on marginal land every five years

    • Making the sector more resilient

57. Soil organic matter in every province increasing by several percent per decade
58. Farm debt cut by 50% by 2040, to aid in financial resilience to climate impacts
59. Financial margins in all agricultural sectors 50% larger by 2040 (via reduced dependence on purchased inputs, etc.)
60. 90% of farms complete (expanded and comprehensive) Environmental Farm Plans (EFPs) by 2030; these could include emission-reduction plans and nutrient/fertilizer-management plans
61. Halting the expulsion of farmers–crucial managers of land, water, soil, & biodiversity–by 2030. Increasing the number of farmers as we move through subsequent decades.

    • Supporting biodiversity

62. 0% rate of wetlands loss by 2030
63. 10% increase in treed area on marginal land every five years
64. By 2040, 10% of Canadian agricultural land in set-aside programs that prioritize rewilding and biodiversity
65. Insecticide and herbicide tonnage are decreased by 10% by 2030 (and 20% by 2040)
66. Biodiversity on a broad set of measures (insects, birds, plants, animals, soil biota, etc.) is increasing by 2040
67. Both in-field (crop rotations and diversity) and whole-landscape biodiversity (outside of fields, too) is increasing ○ Supporting water quality and availability
68. Wetlands loss falls to zero by 2030 and then area and number are increasing
69. Losses of nitrate to groundwater are cut by half by 2040
70. Pesticide contamination of surface waters is cut by half by 2040
71. Fertilizer run-off to surface water is cut by half by 2040 (restrict fall application?)

    • Improving soil health

72. A 10% increase in soil carbon sequestration tonnage every 5 years
73. Area planted to cover crops is doubled every 5 years
74. A 10% increase in the length/area of tree rows, hedgerows, and fence rows in every province every 5 years. 

Final Questions:

➣Do you have any other ideas, comments, feedback or suggestions to share on a Sustainable Agriculture Strategy?

See the list of lettered points (A–O) above. Stress the need for bold and rapid action, transformative change, and authentic sustainability.

Thank you! Thanks for taking the time to read this and to provide your input into AAFC’s SAS consultation process. This is very important work. The NFU can play a crucial role.