On behalf of our members and the agricultural input supply and service industry, IFCA has submitted detailed comments to Illinois EPA on the proposed Nutrient Loss Reduction Strategy.  To view IFCA's comments (a seven page document), click here.  We encourage our members to read our comments, and to submit your own as well.  The comment period ends on January 25, 2015.  More on the ILNRS can be found on our website at www.ifca.com.  

 

IFCA expressed our desire to work with IEPA and IDA by providing the resources of an industry Agronomic Technical Committee to help replace many assumptions on nitrogen and phosphorus practices with more practical applications that we feel will reduce nutrient losses without harming the agricultural economy.  We also point out that costs associated with recommending moving all nitrogen applications to a spring season only are severely understated in the document.  The strategy estimates an increased cost to the farmer of $18 per acre to move all nitrogen application to the spring.  We provide an illustration of the true cost of nitrogen production, infrastructure, transportation, equipment and human resources and estimate the cost would be upwards of $194 per acre.  We also reflect on changes already occuring in the industry that are increasing nutrient use efficiency and utilization, such as stewardship of fall applied nitrogen, splitting nitrogen applications and educating our farmer customers on proper nitrogen rates and enhanced efficiency products.  

 

If you wish to send in comments from your company or individual perspective, you may email them to simon.daniels@illinois.gov.  In the subject line of your email and your comments please reference the ILNRS.  

 

At the IFCA Convention on January 20 and 21, we will have special CCA sessions as well as a special ILNRS panel in the general session, giving the perspective of IEPA, IDA and the U of I Science Assessment that helped to estimate the nutrient loss mechanisms in Illinois.  We hope to see you at the convention where you can learn more about the ILNRS and what IFCA is doing to assure our industry can lead and help our farmer customers reduce nutrient losses to achieve the goal of keeping our nutrients for the crop, and protect water quality here in Illinois and in the Gulf of Mexico.  

 

If you have questions about the ILNRS, please contact Jean Payne, Dan Schaefer or KJ Johnson on the IFCA staff.  You will be hearing much more about this and IFCA will provide tools and expertise as our members face this new opportunity.  The ILNRS is not a regulatory document for agriculture, but there is intense pressure to show that we can reduce nutrient losses in order to assure voluntary and industry-led efforts over onerous regulations in this area of production agriculture.  We must deliver on that expectation.