ALUS is gravely flawed

Elizabeth Brubaker
Ontario Farmer
April 21, 2009

The new Ontario ALUS Alliance proposes incentives rather than regulations to encourage farmers to protect the environment. The Alliance’s market friendly rhetoric obscures its reliance on tools that are antithetical to markets: taxpayer subsidies and violations of rural residents’ property rights.

ALUS stands for Alternative Land Use Services. Farms, of course, don’t just produce food, fibre, and fuel. Managed properly, they can also provide "alternative" ecosystem goods and services — they can filter our water, store carbon in soils and plants, control flooding, create fish and wildlife habitat, and provide the rural landscape that so many of us love.

Although such ecosystem services have enormous value, farmers have few economic incentives to provide them. The ALUS Alliance aims to change that. It argues that since the public benefits from farmers’ conservation efforts, it should share the costs. The public should purchase environmental services from farmers at fair market value.

Support for ALUS is snowballing. The Canadian Federation of Agriculture has thrown its weight behind the program, as have the National Farmers Union and the Christian Farmers Federation of Ontario. Politicians and bureaucrats have endorsed ALUS. The federal government, Manitoba, and Ontario have helped fund ALUS pilot projects, and PEI has adopted it as provincial policy. Adding their support are conservationists — not just of the hunter variety, but also traditional environmental organizations like Ontario Nature and the Sierra Club.

But ALUS is gravely flawed: It fails to distinguish between providing an environmental good and preventing (or correcting) an environmental harm. It rightly rewards farmers for providing environmental services, but wrongly rewards them for repairing environmental damage. It makes sense to pay a farmer to provide waterfowl habitat or green space — something he is not otherwise required to do. Indeed, requiring a farmer to provide such social benefits for free amounts to expropriation without compensation. But it does not make sense to pay a farmer to keep his cattle’s manure out of local streams — something he should be required to do without subsidies.

Paying farmers not to pollute defies a widely accepted economic principle at the heart of environmental sustainability — the need to internalize the costs of pollution, or make pollution prevention part of the cost of farming. It replaces "polluter pays" with "polluter gets."

Paying farmers not to pollute also makes a mockery of our environmental laws, both ancient and modern. The common law prohibits the corruption of watercourses, and treats water pollution as a violation of downstream residents’ property rights. The statutes that have largely taken the place of the common law likewise prohibit water pollution. Under these laws, pollution is met not with rewards but with penalties.

Because farmers should have no right to pollute local waterways, projects that reduce water pollution shouldn’t qualify for taxpayer support. But they do. Farmers participating in the ALUS project now underway in Norfolk County can earn $150 per acre for three years if they plant buffer strips of trees or other vegetation on creek banks to reduce erosion, filter runoff, provide habitat, and cool the water. ALUS calls one buffer project that has visibly improved water downstream quality a "huge success," boasting that the stream bed quickly filled with watercress, which grows only in cool, clean water. It doesn’t ask if the farmer previously had any right to pollute that stream, or why he should be paid to stop doing so.

Other schemes to pay farmers for the environmental services they provide likewise support projects to improve water quality. In Huron County, a Payment for Ecological Goods and Services pilot project pays farmers to retire lands along watercourses. In exchange for $250 per acre per year for five years, farmers are restricting their livestock’s access to the water and planting trees. Again, supporters fail to ask why the farmers were ever allowed to let their cattle erode stream banks or urinate and defecate in water that those living downstream relied on, or why they should be paid to stop such polluting practices.

Paying farmers to remedy environmental problems that they themselves have created is bad economic policy and bad environmental policy. The ALUS Alliance should redesign its program to create markets for legitimate environmental services and respect private property rights.

Responses to this article


A small bit of truth can be a dangerous thing

by Jeffrey Carter, Rural Voice, June 2009

It’s like those promoting war who claim God is on their side. While that may be true, God is on the other side as well or, perhaps, God simply is.

So what passes for truth becomes both armour and weapon. And the opposing sides batter themselves to bloody bits over their perceived irreconcilable differences.

Similar situations arise in Canada with farming and food — though it seldom comes to violence.

A letter to the editor in the April 21 edition of the Ontario Farmer brought this to mind. Elizabeth Brubaker, executive director of Environment Probe Toronto, leveled criticism at the some aspects the Alternative Land Use Services concept.

ALUS is more than just about the production food, fibre and fuel. The idea is to also reward or compensate farmers when they support a healthy environment through such things as carbon sequestration, flood control, the creation of wildlife habitat and water filtration.

What Brubaker takes exception to is the extent to which farmers should be supported with public dollars.

"(ALUS) . . . fails to distinguish between providing an environmental good and preventing (or correcting) an environmental harm. It rightly awards farmers for providing environmental services but wrongly rewards them for repairing environmental damage."

Brubaker goes on to describe the creation of green space as a true environmental service. That can involve the sacrifice of productive agricultural land, something for which she says farmers should certainly be compensated for.

In contrast, Brubaker says public dollars shouldn’t go to things like keeping cattle out of watercourses or even planting buffer strips along streams.

"(ALUS) . . . supporters fail to ask why the farmers were ever allowed to let their cattle erode stream banks or urinate and defecate in water that those living downstream relied upon, or why they should be paid to stop polluting practices."

Brubaker has a valid point but the situation may not be quite as black and white as she contends.

There’s the historical context to consider.

Ontario farm families have been working farmland to the edge of ditches, streams and other places where water flows for generations. Ontario cattle have been wading into streams for just as long.

Opposition to such practices has only become widespread as society has measured and become aware the negative impacts. From the perspective of many farmers, the loss of productive agricultural land without compensation remains a sorry blow, regardless of the green implications.

There is also a question of context.

Brubaker may not be aware that the economic challenges facing the agricultural community or of how farmers, by holding off-farm jobs, have for decades have given a lot more than they’ve taken. It can also be said that many farm families have a long record of providing environmental benefits to society without compensation — beyond the good will it may have generated.

Directing public funds through ALUS projects for environmental improvements might well be construed as payback.

There are, of course, instances in which Brubaker’s view is perfectly valid. Farmers who pollute in a blatant way — such as intentionally directing manure down tile drains — should never be rewarded for their activities. Rather, their butts should be nailed to the wall.

Dialogue is warranted.

Brubaker is well intentioned, well informed in many respects but may not have perfectly clear picture of the entire situation.

Jeffrey Carter is a freelance writer who specializes in agriculture, food and natural resources.



Ontarians serious about environmental quality have to put up some money

by Tristan Knight, Ontario Farmer, May 5, 2009

Dear Editor:

Elizabeth Brubaker’s recent letter to Ontario Farmer, "ALUS is gravely flawed", is a concise and welcomed critique of the ALUS approach. ALUS is predicated on adequately compensating farmers with annual payments for provisioning ecological goods and services from agricultural land, of which society benefits. The approach has received quite a bit of fanfare over the past few years, and it is time for a thoughtful discussion of its merits and demerits.

Ms. Brubaker cautions that ALUS does not distinguish between providing an environmental benefit to society beyond what is legally required (say, wildlife habitat or green space), and reducing an environmental harm that is prohibited under common law and/or statutory law in the province. The distinction is subtle but should be formally addressed before ALUS can be scaled up to the provincial level and made permanent, the foremost goal of the Ontario ALUS Alliance.

Despite Ms. Brubaker’s criticism, however, I contend that her concern is overstated. She asserts that "it does not make sense to pay a farmer to keep his cattle’s manure out of local streams — something he should be required to do without subsidies".

Yet, at Norfolk, farmers are predominately involved in retiring swatches of marginal or environmentally significant land, which are then restored to tall-grass prairie, oak-savanna, or wetland. The vast majority of payments target environmental benefits well above what might be construed as due diligence.

The program at Huron targets planting buffer strips, which Ms. Brubaker would consider problematic since the Nutrient Management Act mandates vegetated buffer zones along streams at least 10 feet wide if nutrients are applied to an adjacent field. Fortunately, program administrators require that buffers be at least 30 feet wide to receive payment (three times greater than legally mandated).

Of course, as Ms. Brubaker points out, both ALUS-type pilot projects do offer funding for certain practices (i.e. fencing cattle out of streams) that the public might deem objectionable in light of legal obligations such as nuisance and trespass laws and statues such as the Nutrient Management Act and Ontario Water Resources Act.

But this does not negate the fact that inspecting and charging copious farmers for generating non-point source agricultural pollution remains overly impractical. Indeed, much of the land adjacent to streams enrolled at Huron had been under productive uses for decades despite the law and the availability of cost-share assistance through the Environmental Farm Plan and local conservation authority to vegetate and fence off the stream bank.

I am not suggesting farmers should be allowed to pick and choose which regulations they are willing to recognize, only that in certain circumstances the use of punitive "sticks" should be coupled with financial incentives if the capacity to comply with (hampered by lagging farm incomes) or enforce agri-environmental standards is limited or overly burdensome. ALUS can help to reduce the need for regulatory action.

In the United States, the Environmental Quality Incentives Program (EQIP) explicitly assists farmers with meeting "federal, state, tribal, and local environmental regulations". Through EQIP, US taxpayers expend millions of dollars to farmers each year for "something they should be required to do without subsidies".

Proponents of ALUS must critically consider which best-management practices should receive program payments, as Elizabeth Brubaker suggests. But including fences and buffers in ALUS is not necessarily "bad economic policy and bad environmental policy", especially when ALUS payments are intended to complement existing regulation. If Ontarians are serious about improving environmental quality both on and off the farm, we must be willing to shoulder a greater proportion of the cost of improving the environmental performance of agriculture. ALUS typifies such an approach.

Tristan Knight is a Masters Candidate in Environmental Studies at York University.



Farmers committed to the health of nature that feeds us

by Grant Robertson, Owen Sound Sun Times, May 2, 2009

Alternate Land Use Services (ALUS) was designed to reward farmers for the actions they take to protect and enhance our environment.

This could include protecting waterways from potential contamination, restoring wildlife corridors or planting native grasses to support songbirds, just to scratch the surface of potential environmental goods and services provided to society by farmers.

If you go to the ALUS website at you will find the principles under which the ALUS concept operates. One of the key principles of ALUS is the consideration of "payments for the maintenance of existing natural assets, particularly where a viable alternative exists for converting natural assets into other (agricultural) uses." By this it is meant that farmers have choices they can make in terms of the use of their private lands. Farm income has been so low for so long that a great many farmers across a lot of commodities and from very different sized farms have had to take off-farm income just to pay their daily bills. Spending money that does not increase farm income is an unlikely occurrence. With few real economic choices available to farmers, incentives made available through programs like ALUS are the best possible way to get the necessary environmental actions we need as a province.

Recognizing the potential for positive change that ALUS represents, the NFU in Ontario has been a long-term supporter of the concept. Many NFU members have been a part of trying to spread the ALUS program beyond the borders of Norfolk to all of Ontario. NFU members recognize the fundamental role farmers play in the stewardship of our water, wildlife and land. The NFU has been in the foreground of the fight for a sane food system that also protects the future health of the nature that feeds us.

Given the NFUs strong record on protecting our land and water it was quite surprising to see ALUS being attacked by a self-described environmentalist representing a group that supports the privatization of water in the April 21 edition of the Ontario Farmer. Environment Probe, a downtown Toronto based organization, boasts as members of its board of directors a few columnists like Andrew Coyne and Margaret Wente, a few professors, a couple of businessmen, and a lawyer, none of whom seem to have much understanding, let alone involvement, in making on-the-ground decisions regarding protecting our natural heritage for future generations.

What seems to have set Elizabeth Brubaker, executive director of Environment Probe off is the possibility that farmers might receive payments for taking land out of production that might come to the side of a waterway rather than suing or charging farmers for doing the very things they have been encouraged to do. Clearly Environment Probe does not believe that overcoming false divisions through a positive and collaborative approach such as those of ALUS is necessary.

However, this is the approach taken daily through our general tax revenues in overcoming the collective environmental damage caused by the urban landscape. Ontarians have collectively contributed for the cleanup of pollution created by the urbanization that has occurred in places like, well the street outside Environment Probe’s offices. It is that collective action for change that is necessary in both rural and urban Ontario.

It is a real shame to see people from environmental groups, farm organizations, municipal governments and many other societal sectors being taken to task for supporting positive, collaborative action by an organization grounded in ways of thinking that would rather encourage an urban/rural divide instead of a future that will benefit most the strongest environmentalists I know: my three children.

Grant Robertson is a senior elected official with the National Farmers Union-Ontario and a national board member of the NFU. Robertson and his family farm near Paisley.



Why did Environment Probe go public?

April 28, 2009, Ontario

Dear Editor:

No doubt many have read Elizabeth Brubaker‘s letter "ALUS is gravely flawed" in the Ontario Farmer including those in various government ministries. What is the matter with environmentalists (and farmers) anyway that they publicly attack each other without trying first to resolve differences?

Surely, Environment Probe could have expressed concerns and received answers before writing a letter to the editor. Did Probe think their concerns would not be heard? Now, when the ALUS Alliance goes to those ministries to have discussions about proposed Provincial Policy creation and public funding, the Alliance could be met with the argument that has been used against farmers for so long, that we are divided and confused in what we want.

Elizabeth Brubaker is correct to say that we should not externalize the costs to prevent pollution, neither should corporate industry. Ideally, internationalizing the costs applies to farmers as well as corporations and individual citizens. We had this discussion when the Environmental Farm Plan (EFP) was first implemented years ago.

It went something like this: if farmers regard themselves as such good stewards of the land and want to continue to be regarded as salt of the earth people, then why should society pay the costs of remediation of pollution originating from farms? In effect, the answer farmers and the government provided was that farmers could get enough from the marketplace to carry out the stewardship that they so ardently wanted to practice. The overwhelming success of the EFP is a measure of farmer’s desire to engage in good stewardship.

If Ms. Brubaker wants people in Ontario to pay the true costs of food in the marketplace, then please pay more so that farmers get enough from their markets to be good stewards because we really do want to be good stewards of the land. But, as long as federal and provincial governments practice cheap food policies, where only 9% of Ms. Brubaker’s annual income is spent on food and she has earned enough in the first part of January to buy her family’s food for a year, good stewardship is not as likely to happen as it would with some financial stimulus.

Large corporate industry is encouraged with monetary incentives to clean up their pollution and they have had years of profits to pay for it themselves. Beef farmers have not had a profit since 1989. They are earning half what they did annually from 1942 to 1989 and do not have any capital left over to improve their practices. So, with the Environmental Farm Plan, at least, society has agreed to help with some monetary support.

The Alliance too is asking for taxpayer assistance. The real attraction is that ALUS is voluntary, is farmer encouraging farmer, and driven by moral as opposed to legal obligation. There will probably be less public cost than there would be to have government enforcement under some form of legal obligation and the penalties that Ms. Brubaker advocates.

Couldn’t Ms. Brubaker’s concerns have been discussed prior to her public rebuke in the media? What does Environment Probe gain by this display of disunity? How does it further the environmental cause? Even if she thought the merits of her argument were not adequately addressed after consultation with the Alliance, at least then she could have been responding to Alliance arguments in her letter when making her points about externalizing costs and bad economic policy. As it is, the letter has only part of the story.

— Rae MacIntyre, President of the Grey Local, NFU-Ontario



ALUS is not rewarding bad stewardship

April 28, 2009, Ontario

Dear Editor

I am a farmer, chair of the Norfolk ALUS Pilot Project and a founding member of the Ontario ALUS Alliance. Recently, a letter was published from Environmental Probe indicating our efforts were "gravely flawed". In fact, the only thing flawed was the portrayal that ALUS rewards bad stewardship.

The Norfolk ALUS Pilot Project is a farmer-led, farmer-driven pilot designed to test the concept of paying farmers for the ecological goods and services they produce on privately farmed land. We are proud that we operate on a community and cross-sectoral level which results in a program that provides environmental benefits for all of society. Our basic premise is this; as society is faced with a multitude of environmental issues, now, more than ever, we must build upon the long-standing stewardship ethic of the Ontario farmer and enlist the farm community to provide environmental solutions. Our governing ALUS Partnership Advisory Committee has representation from the farm, conservation, municipal, government and environmental communities. Together we set policies that have resulted in several hundred acres of farmed land put into environmental service in our first year. More importantly, 31 farm families have become involved in this new venture with 30 some more set to join this spring. ALUS builds upon existing programs like the Environmental Farm Plan and is perfectly positioned to help the Ontario government implement its’ Climate Change Action Plan.

The Ontario ALUS Alliance was formed on March 27th to formally consolidate the broad base of support the ALUS concept has garnered. The purpose of the Alliance is to support the development of a provincial ALUS program. At the founding meeting, 78 different organizations were represented. Of the 78 groups, 19 were farm based, and the majority were from the environment and stewardship sectors. Most of the delegates had attended an ALUS workshop or farm tour to fully apprise themselves of how the project operates. In addition to the Alliance, we are in receipt of letters from three other stewardship groups that would like to see the concept come to their area.

I must thank Environment Probe for pointing out the enormous economic value of farm produced ecosystem service and the snowballing support for our proposals. Clearly, the farm community is an underutilized link to a better environment, with the locally based ALUS concept the way to produce results.

I have personally extended an invitation to Elizabeth Brubaker of Environment Probe to either visit our ALUS demonstration sites, or attend a workshop to gain firsthand knowledge of what farmers can achieve, and put an end to the misconceptions about what ALUS does and doesn’t do. In addition, I have invited Environment Probe to become part of the ALUS Alliance, to become part of the team that is building real environmental solutions. Pointing fingers at the farm community and insinuating farmers are polluters is not getting the job done. It’s time to build bridges now, and come to the table with solutions that work for the farmer, for society, and for our children.

— Bryan Gilvesy, Chair, Norfolk ALUS Pilot Project



Non-polluting comment inaccurate

April 28, 2009, Ontario

Dear Editor:

As one of the "traditional environmental organizations" named in Elizabeth Brubaker’s recent letter to the editor, and an ardent supporter of the ALUS Alliance, it seems that Ontario Nature has little choice but to respond to Ms. Brubaker’s ill-informed criticisms.

Ontario Nature’s mandate is to protect wild species and wild spaces. Our work with the ALUS Alliance has come about because we have realized that without partnerships with the agricultural community, we could never achieve this goal in southern Ontario.

Brubaker’s position that under ALUS farmers are being compensated for "not polluting" is inaccurate and potentially very damaging to the precedent-setting connections that are being built between the environmental and agricultural communities in this province. Under ALUS, incentives are provided to farmers to encourage good stewardship and environmental remediation. These incentives enable farmers to provide essential services such as clean water, sustainably grown crops and habitat for wild plants and animals in a heavily developed landscape under increasing threat from urban sprawl, resource extraction, climate change and the like.

We should no longer expect farmers to shoulder the financial burden of providing these benefits to society.

The ALUS Alliance is fostering connections among environmental, agricultural, local food and stewardship groups in the hope that these partnerships can help southern Ontario maintain its ecological and economic integrity. For this reason, and many others, Ontario Nature is proud to be a founding member.

— Anne Bell, Senior Director of Conservation and Education, Ontario Nature


April 28, 2009, Ontario

Dear Editor:

The recent letter from Environment Probe criticizing the ALUS approach is itself gravely flawed. It creates a number of arguments for why ALUS is either ineffective or inequitable while not addressing a key consideration for seriously considering the program — it works.

Anyone taking the time to visit an ALUS farm will see environmental enhancement and investment in our natural capital. Surely to goodness real, deliverable results trump academic arguments about why a particular approach isn’t suited to a task or is flawed in its assumptions. And to be amongst farmers participating in ALUS initiatives is to know that the approach is all about environmental enhancement, not mitigation for less-than-desirable production practices.

Farmers are natural stewards of the environment and have consistently demonstrated through their actions and organizations that they will partner with others to tackle issues that impact society. ALUS is an extremely pragmatic approach that builds upon that tradition.

— John Clement, General Manager, CFFO


1 thought on “ALUS is gravely flawed

  1. Pingback: Polluting pays off | Environment Probe

Leave a Reply

Fill in your details below or click an icon to log in: Logo

You are commenting using your account. Log Out /  Change )

Twitter picture

You are commenting using your Twitter account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s