Are the nutrient-loading standards based on the precautionary principle, or on actual scientific assessment of damage potential?
DW: I would disagree with that. The residual levels for nitrogen in the proposed regulations are in fact based upon agronomic requirements. These are residuals that a producer can work within which all of our information leads us to believe should not impair productivity. All it will do is assure that the nutrients are managed more precisely on the landscape, to avoid leaving unused nutrients at the end of the growing season. It’s those nutrients that are of interest to us, because it’s those that leach into the groundwater or are lost to surface water. So it’s not a precautionary approach. It’s a very practical approach based upon a recognition of what growing crops can use, and putting in place a mechanism that relies to a large much greater extent in the future on soil-testing than has been the practice in the past. I would say as well, for phosphorus, the first threshold at 60 parts per million is also based upon the same principle. It’s not precautionary, it’s based upon some pret
