OFVGA response to Ontario's Climate Change Discussion Paper

Grape Wind Machine
A wind machine in grape production, one of many adaptations producers have made to environmental challenges. Photo by Denis Cahill, The Grower.


  • The Ontario Fruit & Vegetable Growers’ Association and its members already adopt and use environmentally sustainable practices, and support initiatives to enhance competitiveness and environmental sustainability
  • Policies must be based upon complete science
  • Competitiveness of the sector must not be compromised. Policies on climate change must be integrated with economic sustainability
  • Food security and climate change are intimately related
  • Infrastructure investment is necessary for climate change policies to be effective
  • Long-term research and development, and competitive sector-based focus and implementation are keys to success
  • Carbon pricing strategies must not negatively impact sector sustainability and competitiveness

The Ontario Fruit and Vegetable Growers’ Association (OFVGA) was established in 1859, which makes it one of Ontario and Canada’s oldest farm commodity organizations. As the voice of Ontario’s fruit, vegetable and greenhouse farmers, the OFVGA is a nationally recognized not- for-profit association that advocates on behalf of Ontario fruit and vegetable farmers and the edible horticulture industry, and represents its members provincially, nationally, and internationally.

The sector supports 30,000 farm-based, non-family jobs in Ontario, as well as a further 8,700 jobs specific to horticulture and specialty crops. Over 125 different fruit and vegetable crops are grown in Ontario with an estimated annual farm gate value of $1.6 billion (2013).

Members of the OFVGA are strongly committed to providing safe and efficiently produced food to the consumer. It is in the best interests of producers and consumers that food be produced and delivered in the most efficient manner possible, taking advantages of the most current technologies and innovation to make this so. Fruit, vegetable and greenhouse growers in Ontario must continue to invest to remain competitive in the global landscape.

The OFVGA supports the government’s attempt to enhance our environment and the move to a low carbon economy. Our growers have a long history in adopting technologies and innovation, which improves the efficiency and the environmental foot print of edible horticulture. The following adoptions can be viewed as examples of how edible horticulture producers have adapted to environmental challenges:

  • Wind machines in grape production
  • Water and nutrient recirculation equipment
  • Development of the ever-bearing strawberry
  • Integrated Pest Management has been adopted by fruit and vegetable growers resulting in reduced sprays, field passes etc.
  • Use of Global Information Systems (GIS) technology for vegetable production
  • Use of shading technologies for ginseng production
  • Computerized environmental monitoring of temperature and humidity in greenhouse production
  • Energy Curtains in Greenhouses

Horticulture producers continue to adopt precision agricultural production methods, which leads to highly efficient use of water, fertilizers and other crop inputs. Not only does this enhance the productivity of the farm, it leads to a reduced impact on the environment.

By moving towards a low carbon economy, horticultural producers must adopt new technologies that will support the goal of improving environmental sustainability while at the same time have no negative impacts on the competitiveness of the sector. Due to fierce competition from international jurisdictions (such as Mexico, Peru, Chile, China and elsewhere), our move towards a more carbon neutral economy must not put our growers at a competitive disadvantage. Environmental compliance and its associated costs are less of an issue in these countries so any technologies that are adopted in Ontario must be done so with this in mind. There must be incentives for growers to adopt these new technologies and these could come in several forms.

It is important to consider the concept of carbon leakage – if production of food is moved out of Ontario and to an area that is not addressing carbon, then there is a great and real possibility that this might have a negative impact on climate change. In essence, this would be supporting business in a country that is not addressing climate change. Are we going to lose business to other areas. This should NOT BE! Sovereignty of our food supply must not be compromised and the OFVGA recommends that the development of policies on climate change keep this perspective when the policy is fully developed. This supports the goals of horticultural sustainability (environmental, economic and social components).

Actions and decisions based upon Science-Based Principles. The OFVGA agrees with the government of the Province of Ontario that science-based decision-making will lead to better decisions and policy development. These science-based actions will lead to best management practices, which will be easier for the sector to implement. These must include methods to improve efficiency of production, support the sequestration of carbon and reduce the GHG emissions. These objectives can be met through long-term investments in research and technology innovations and through the active promotion of science-based innovations and technology transfer.

Actions based upon Leadership. The OFVGA agrees that leadership in the climate change issue is of paramount importance. We also agree that decisions on climate change policy must be done in a manner to respect the competitiveness challenges faced by Ontario agriculture so strategies that are brought in place must be accompanied by corresponding mitigation on international production practices.

Actions based upon Learning. The OFVGA agrees that best practices must continue to be employed and that a technology transfer program be put in place for Ontario growers to adopt and implement carbon efficient technologies and practices. Further, for Ontario growers to prosper, experts must be made available to growers to establish best practices. Ontario growers will also need to be given the opportunity to learn, develop and implement technologies, techniques and processes to encourage the most modern adoption of new methodologies. By providing the opportunities to do this will aid in eliciting support from the sector.

Actions based upon Science. The OFVGA agrees that innovations and technology must be based on science that will also enhance the competitiveness of the Ontario producer. New technologies and innovations must be made available to Ontario growers on an on-going basis. For example, Ontario’s tree fruit industry has a tremendous opportunity to enhance the sequestration of carbon. What new technologies can measure, expand and stimulate this sector to become major carbon storers? The greenhouse sector would also have the potential to use excess carbon. Adapting genetics to the Ontario environment, optimizing fertilizer use and 4R (Right Source, Right Rate, Right Time, Right Place) management are other examples which will enhance the Ontario carbon situation. The development of effective “process engineering” processes to optimize the use of carbon (in terms of fuel, outputs, cost, efficiencies) could be a short-term win for the sector.

  • The OFVGA therefore supports investment in sustainable practices, long term funding for research and development to mitigate climate change risk.
  • The OFVGA also strongly recommends the monitoring of the impact of decisions that are made and to adjust accordingly.
  • The OFVGA also supports that these are science-based decisions are truly based upon a full scoping analysis of the science.

Actions that are Economically Integrated. The OFVGA agrees that new technologies and practices that impact the carbon economy must also be adopted in an integrated manner, such that the profitability of Ontario producers is not further eroded. If producers are not competitive, no production will occur, resulting on reliance of foreign based, high carbon economies and impact. The carbon policies of other areas can have a direct link to local food supply. These policies must be considered as they impact the ability of local producers to supply product through the retail chain. Because Ontario-based producers do not have the ability to pass on added costs to through the value chain, it is essential that Ontario based policies be such that they do not impede the competitive position of these local producers.

Actions that are Market Based and Productive. The OFVGA agrees that the market based and production and efficiency enhancement will enhance the competitiveness of the Ontario producer. However, actions that are above and beyond the net benefit to the producer would have negative repercussions, and therefore could not be supported.

Actions that support Well-Built “Climate Smart” Infrastructure. The OFVGA agrees that there is a need for large expansion of rural infrastructure, from transportation systems, electricity transmission and smart grid development, internet capacity and power generation. Combined heat and power (CHP) infrastructure, efficiency of heat production, including investments in natural gas distribution will all contribute to smart infrastructure investments. This will involve significant investment on the part of three levels of government (municipal, provincial and federal). Further, investments in climate change related infrastructure (water, power, transportation) will enhance the competitiveness of Ontario producers.

Actions must be Flexible. The OFVGA agrees that due to the diversity of the carbon economy there must be a modicum of flexibility across sectors. The horticultural sector is diverse, and the use and sequestration of carbon varies amongst the members of the OFVGA. We encourage OMAFRA to enhance its presence in the edible horticultural sector, particularly to support adaptation of best management practices and to provide education on new, carbon friendly techniques, technologies and processes.

Actions must be based on Collaboration. The OFVGA agrees that there are many opportunities to adopt technologies that are developed elsewhere. Further, it is recognized that producers and other members of the value chain as well as non-related industries will have the opportunity to collaborate in the development of carbon friendly technologies.

Actions must Assess Risk. The OFVGA agrees that prior to any carbon pricing or cap & trade program implementation that a full and comprehensive risk assessment to the competitiveness of Ontario producers be conducted. Further, upon implementation of any program, the short- term and long-term aspects of the risk to the producer must be communicated, tracked and re-evaluated such that the best practices can be adopted and implemented in a cost effective manner.

To create an even playing field, Ontario should have a policy where Ontario has the right to levee a carbon fee on all products that land in our markets. This carbon fee could compensate for the difference in carbon contributed to the atmosphere as compared to producing the product in Ontario. Since most of carbon emissions come in transportation, the OFVGA considers that the Ontario carbon plan can level the cost of imports by a carbon fee to reflect the carbon expelled getting those product here. That fee would help support price being paid by Ontario producers.

The OFVGA recommends that long term funding for Research and Development to mitigate climate change risk and the associated impact on competitiveness of Ontario based producers be a key component of climate change policy. Since other jurisdictions may not be in the same position, Ontario must develop strategies to have local growers at the forefront of new technologies, processes and procedures to ensure the sustainability of the sector. This will also provide for some certainty for the secure supply of locally produced food for Ontario consumers. Food security and climate change policies are intimately related.

It is recommended that the government of Ontario implement a cost share funding program to encourage the adoption of those technologies, techniques and processes that will support environmental sustainability, including those to mitigate the impacts of climate change.

To effectively price carbon one must have the goal of reducing greenhouse gas emissions while at the same time retaining or enhancing the competitive base of production. In other words, improve the efficiency of production using less carbon per unit production. This can be done by incentivizing emitters to reduce carbon emissions and to encourage sequesters of carbon which will lead to a net low carbon economy. High carbon users will be dis-incented through the requirements for permits to emit carbon.

It is essential that any carbon-pricing scheme not put Ontario producers out of business. A concern is that other jurisdictions that do not have requirements for carbon could be put in a competitive advantage position, not only in term of production, but also in terms of attracting businesses from Ontario. Since food security and carbon pricing strategies are directly related, the potential effects of new policies must be fully assessed to determine potential impacts on local supply conditions. Further, if local food supply is compromised, then the objectives of the Climate Change Discussion Paper will not be met if food supply is provided even more by foreign jurisdiction (different methods of production, long transportation runs to Ontario, further development of areas which are required globally for environmental stability – e.g. the Amazon rainforest in South America).

All of the improvements to carbon efficiency must be done with the understanding that the competitiveness of the producer not be compromised. A uniform carbon tax model, in our opinion, would not meet this requirement, as costs from input suppliers would be uniformly passed on to horticultural producers. Because this sector’s growers are price takers, there is little to no opportunity to pass down the added costs of production through the value chain. And often is the case when the end users demand tighter pricing models. While this might result in a net increase in revenue to the government, the objective of lowering carbon impacts may not be met.

The use of a Cap & Trade system would encourage emitters to find ways to become more efficient, and also encourage those who sequester carbon to become even better at that activity. This will also potentially create a new revenue stream for some horticultural producers through the sale or auction of carbon credits.

The Ontario Fruit & Vegetable Growers Association considers this consultation process to be appropriate. The OFVGA applauds the government of Ontario for providing opportunity to comment on a policy which is in development. The OFVGA is supportive of the government in its attempts to create a competitive environment for horticultural growers and the acknowledgement that growers must remain profitable. Policies that are brought forward must keep this in mind for Ontario to have a stable, secure supply of locally produced food. 

Click here to download a PDF copy of "OFVGA's response to Ontario's Climate Change Discussion Paper".


Dr. John Kelly, Executive Vice President
Ontario Fruit and Vegetable Growers' Association
105-355 Elmira Road North
Guelph, ON N1K 1S5
519-763-6160 x115

Mark Wales
Section Chair
Ontario Fruit and Vegetable Growers' Association
105-355 Elmira Road North
Guelph, ON N1K 1S5

Dr. Justine Taylor
Energy and Environment Co-ordinator
Ontario Greenhouse Vegetable Growers
32 Seneca Road
Leamington, ON N8H 5H7
519-326-2604 x205