## Changes to the US Renewable Fuel Standard Program: Petition for an Aggregate Compliance Approach for Canadian Crops and Crop Residues



# Data Comparability, Analysis and Justification

January 21, 2011

Prepared by Agriculture Division, Statistics Canada for Agriculture and Agri-Food Canada

### 1 Changes to the US Renewable Fuel Standard Program: Petition for an Aggregate Compliance Approach for Canadian Crops and Crop Residues

Data Comparability, Analysis and Justification

1.0 Background

1.1 The United States established a Renewable Fuel Standard program in 2005 through the passage of the Energy Policy Act of 2005. The Energ y Independence and Security Act of 2007 (EISA) expanded the program and included, a mong other things, a definition of “renewable biomass” that includes “planted crops an d crop residue harvested from agricultural land cleared or cultivated at any time prior to [December 19, 2007] that is either actively managed or fallow, and nonforested” (42 U.S.C. §7545(o)(1)(I)). The United States Environmental Protection Agency (EPA) promulgated regulations implementing these amendments on March 26, 2010, de fining certain agricultural lands as “existing agricultural land” eligible to meet th is definition (75 Fed. Reg., No. 58, p. 14,692-3, March 26, 2010). EPA’s regulations includ ed provisions for establishing compliance with the renewable biomass definition. A mong the compliance provisions is an “aggregate compliance approach” for planted crop s and crop residues grown in the United States. On December 9, 2010, EPA promulgated additional regulations (75 Fed. Reg., No. 236, §80.1457) that laid out conditions f or a similar approach for planted crops and crop residues grown outside the United St ates.

1.2 The regulatory provision of the Renewable Fuel Standard program ( RFS2) rule of the EPA, published on December 9, 2010, establishes cri teria and a petition process for application of the aggregate compliance approach fo r planted crops and crop residue in foreign countries. A foreign country submitting a p etition for an aggregate compliance approach is required to provide EPA with reasonable assurance that specified renewable fuel feedstocks from the foreign country meet the d efinition of renewable biomass and

will continue to meet the definition of renewable b iomass, based on the submission of credible, reliable and verifiable data. In determin ing whether these requirements have been met, EPA will consider the following specific factors:

(a) 

### A reasonable identification of the aggregate amount of agricultural land in the foreign country as of December 19, 2007 that was av ailable for the production of eligible feedstocks (i.e., feedstocks that satisfy the definition of renewable biomass);

(b) 

### Information from years preceding and following 2007 showing that the identified aggregate amount of land, termed as the 2007 baseline area of land (also referred to herein as 2007 baseline acreage), is not likely to be exceeded in the future;

(c) 

### Historical land use, agricultural practices, econom ic considerations, legal constraints and other factors showing that in futur e, producers of the feedstocks

### 2 will likely continue to use agricultural land withi n the identified baseline acreage as opposed to clearing and cultivating land not eli gible under the 2007 baseline;

(d) 

### A reliable method to evaluate on a continuing basis whether the 2007 baseline area of land is being or has been exceeded; and

(e) 

### A credible and reliable entity has been identified to conduct data gathering and analysis needed for an annual EPA evaluation of the aggregate compliance approach.

1.3 In the final RFS2 rule of December 9, 2010, EPA noted that in developing the regulations for the aggregate compliance approach f or foreign countries, the agency relied substantially on the approach it used for th e United States (75 Fed. Reg., No. 236, page 76,819). The petition process for an aggregate compliance approach for foreign countries, as outlined in paragraph (b) of §80.1457 (75 Fed. Reg., No. 236), requires that a petition must include all of the following o r an explanation of why it is not needed for EPA to consider the petition:

(a) 

### Maps or electronic data identifying the boundaries of the land for which the petitioner seeks approval of an aggregate complianc e approach;

(b) 

### The total amount of land that is cropland, pasturel and, or land equivalent to U.S. Conservation Reserve Program (CRP) land that was cl eared or cultivated prior to December 19, 2007 and that was actively managed or fallow and nonforested on that date;

(c) 

### Land use data that demonstrates that the identified land is cropland, pastureland or land equivalent to U.S. CRP land that was cleare d or cultivated prior to December 19, 2007, and that was actively managed or fallow and nonforested on that date;

(d) 

### Historical land use data for the land within the sp ecified geographic boundaries up to the current year;

(e) 

### A description of any applicable laws, agricultural practices, economic considerations, or other relevant factors that had or may have an effect on the use of agricultural land within the specified geographi c boundaries, including information regarding the efficacy and enforcement of relevant laws and regulations; and

(f) 

### A plan describing how the petitioner will identify a credible and reliable entity who will, on a continuing basis, conduct data gathe ring, analysis, and submittal to assist EPA in making an annual determination of whether the criteria for an aggregate compliance approach remain satisfied.

The petition addresses each of these requirements, all of which support the approval of an aggregate approach for Canada, as is provided fo r the United States. 1

1 Pursuant to §80.1457(b)(7) of the final RFS2 rule dated December 9, 2010, the petition is submitted b y Agriculture and Agri-Food Canada on behalf of the G overnment of Canada.

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1.4 To determine the total acreage of existing agri cultural land in the United States on the date of EISA enactment, EPA obtained from the USDA data representing total cropland (including summer fallow), pastureland, and CRP lan d in 2007. The CRP program lands considered by EPA include the general CRP, the Cons ervation Reserve Enhancement Program (CREP), and the Farmable Wetlands Program ( FWP). EPA relied on two main sources for these data: the Farm Service Agency (FS A) Crop History Data and the USDA Census of Agriculture (2007).

II. SUPPORT FOR AN AGGREGATE COMPLIANCE APPROACH FO R CANADA

A. Canada has credible, reliable and verifiable dat a similar to that for the U.S.

Similar to the U.S. data sources relied on by EPA, there are two Canadian data sources

that EPA can access for a reliable estimate of exis ting agricultural land in Canada 2 

### . The first is the Census of Agriculture (taken every fiv e years) and the second is the annual survey data on cropland collected and published by Statistics Canada. For the data on Canadian agricultural lands that are similar to U.S . CRP lands, EPA can rely on Statistics Canada’s estimates based on the agency’s Farm Environmental Management Survey data collected every five years after the ce nsus year.

2.0 The Census of Agriculture

2.1 Canada has been collecting agricultural data t hrough a census since 1871. Until 1951, the frequency of collection was every 10 years. By 1956, the Census was conducted every five years covering the entire country. The C ensus of Agriculture data provide comprehensive information on agricultural land use which includes data on cropland area, summer fallow, seeded pasture, natural land f or pasture, woodlands and wetlands and all other land, and some information on land ma nagement practices. The Census data are also used to update the national Farm Regi ster 3 

### from which samples are drawn for other agricultural surveys.

2.2 After collection of Census of Agriculture data , Statistics Canada conducts a thorough data analysis and validation. This includes compari ng the data with previous census results, current agricultural surveys and administr ative sources. Errors are identified and corrected, and where necessary, respondents are con tacted to verify their responses. A committee reviews certification reports, containing results of the analysis and recommendations for publication. These procedures a re imposed to ensure the quality of

2 The United States and Canada already share inform ation on technical aspects of collection and proces sing of agricultural statistics on a bilateral basis and th rough the North American Tripartite Committee on Ag riculture

Statistics. Both countries benefit from such inform ation sharing as collection and processing systems are often adjusted to evolving processes and technologies sub ject to individual limitations.

3 The Farm Register is the repository of information for all Canadian agricultural operations. It is th e primary source and control for the collection and coverage of the Agriculture Division’s survey programs and t he Census of Agriculture.

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the published census data. In addition, follow up s urveys are conducted for farms that may have been missed. The 2006 Census had a 3.4% un dercoverage rate for farms,

which accounted for about 1.3% for the total farm a rea (about 1.6 million acres).

2.3 Specific details regarding the 2006 Census of Agriculture concepts, methodology and data quality can be found at http://www.statcan.gc. ca/pub/95-629-x/2007000/4123850- eng.htm. Selected historical data from the Census o f Agriculture can be extracted at no cost from Statistics Canada’s website (http://www.s tatcan.gc.ca/pub/95-632- x/2007000/t/4185570-eng.htm). Copies of the Census of Agriculture questionnaires can be found at http://www.statcan.gc.ca/ca-ra2006/q-en g.htm.

2.4 For the United States, EPA has used in its mea surement of existing agricultural land under the RFS2 the sum of cropland, summer fallow, pastureland, and CRP lands. With the exception of CRP lands, which are part of a USD A program for U.S. agricultural lands, 4 

### these data categories are collected and tracked in Canada through the Census of Agriculture. These data are available in the public domain and are reliable to determine the total acreage of existing agricultural land sim ilar to that determined by EPA for the United States and consistent with the requirements of EISA.

2.5 In Canada, these data are collected, analyzed and disseminated under the authority of the Statistics Act by the country’s national statistica l agency, Statistics Canada. In both countries, the Census of Agriculture is the leading source of facts and figures about agriculture. Both the USDA Census of Agriculture an d the Canadian Census of Agriculture are conducted every five years 5 

### , and participation is required by law in both countries. Table 1 in Appendix 1 contains a list of the terms used by EPA to determine the total acreage of existing agricultural land, th e relevant land usages as categorized in the USDA Census of Agriculture and their equivalent s in the Canadian Census of Agriculture.

3.0 Annual Data on Cropland Collected through Surv eys

3.1 In addition to the Census of Agriculture, the Canadian agriculture statistics program includes surveys of field crops and hays, fruits an d vegetables, potatoes, and greenhouse, sod and nursery products. Among these, a Farm Survey for field crops (including hay) is conducted six times per year to collect information on seeding intentions, area actually seeded, area harvested, y ield, production and stocks of grains. For the Atlantic Provinces, a farm survey is conduc ted twice a year which contains both

4 While Canadian lands are not part of the CRP, cro pland used by farmers for similar conservation purp oses are tracked and reported separately and, as described f urther below, should also be included as “existing agricultural lands.” Binary (yes or no) data on conservation pra ctices are collected during the Census of Agricultu re. In 2006, about 36.9% Canadian farms reported maintaining win dbreaks or shelterbelts, about 19.6% farms reported having buffer zones around water bodies and about 1 0.5% reported green manure practices where green cr ops were plowed down (available at: http://www.statcan.gc.ca/pub/95-629- x/2007000/4182415-eng.htm).

5 The Canadian Census of Agriculture is conducted i n years ending in 1 and 6, while the USDA Census of Agriculture is conducted in years ending in 2 and 7

.

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crop (including hay) and livestock components. The Survey of Fruits and Vegetables is conducted twice a year and the other surveys, once a year.

3.2 The samples for the surveys are drawn from the national Farm Register (FR). Until July 2008, the Register used to be updated annually usin g information from the Census of Agriculture and the annual Farm Update Survey (FUS) conducted between the censuses. In July 2008, the FUS and the Enquête administrative du Registre (ENAR) were

combined under the umbrella of the Continuous Frame Update (CFU), which enabled updating the FR every three months.

3.3 A stratified sampling procedure is applied in drawing the samples and the estimates are validated by comparing with the Census of Agricultu re data and the results of the previous surveys, and in a number of cases, through data validation agreements with the provincial agricultural statistics departments. Dat a quality is measured by the coefficient of variation (CV), which is calculated as the squar e root of the variance of an estimate divided by the estimate itself. A 95% confidence in terval (meaning that 95% of the time one could expect a sample of the same size to give an interval that contains the true population value and 5% of the time the true popula tion value would be outside of these bounds) is also created.

3.4 Estimates for field crops, specialty crops, ha y and forage, root crops (potatoes and sugar beets), fruits, vegetables, and summer fallow areas are derived from the surveys mentioned above and are published on Statistics Can ada’s website. 6 

### The estimates are also published on CANSIM, the agency’s key socioeco nomic database. 7



### 4.0 Data on Agricultural Land under Conservation Pr actices

4.1 Canada does not have any federally funded prog ram for conservation of agricultural land directly comparable to the Conservation Reserv e Program (CRP) 8 

### and the Farmable Wetlands Program (FWP) 9 

### or any province-federal initiative comparable to t he

6 The data are published on Statistics Canada’s web site in PDF format, which can be accessed free of c harge from the links at: http://cansim2.statcan.gc.ca/cgi -win/cnsmcgi.pgm?Lang=E&ResultTemplate=/Stu-Etu/Stu

Etu3&ChunkSize=25&AS_Theme=920&ChunkStart=1&AS_Date =.&AS_Ser=.&AS_Auth=.&AS_Srch=&AS_
SORT=0&AS_UNIV=3&Version=2&AS_Mode=2.

7 The data on CANSIM are available in various databa se formats at: http://cansim2.statcan.ca/cgiwin/CNSMCGI.EXE?LANG=E&RootDir=CII/&CANSIMFILE=CII/ CII_1_E.htm. These data can be accessed for a nominal charge.

8 The CRP is a voluntary program for agricultural l andowners who establish long-term, resource conserv ing covers on eligible farmland. USDA Farm Service Agen cy, Conservation Reserve Program

, http://www.fsa.usda.gov/FSA/webapp?area=home&subjec t=copr&topic=crp. It is intended to protect topsoil from erosion, reduce water runoff and sedimentation , and provide wildlife habitat. Id.

9 The FWP “is a voluntary program to restore up to one million acres of farmable wetlands and associat ed buffers by improving the land’s hydrology and veget ation.” USDA Farm Service Agency, Farmable Wetlands Program , http://www.fsa.usda.gov/FSA/webapp?area=home&subj ect=copr&topic=fwp. Eligible producers in all states can enroll eligible land in the FWP through the CRP. Id.

### 6

Conservation Reserve Enhancement Program (CREP) 10 

### in the United States. However, Canadian farmers follow conservation practices on l ands available for crop production similar to those promoted by these programs for lon g-term environmental benefits such as soil erosion reduction, wildlife habitat conserv ation, water quality maintenance etc., which are tracked and reported separately in both s urvey and census data. The conservation practices followed by Canadian farmers include growing windbreaks or shelterbelts, leaving seasonal and temporary wetlan ds out of cultivation, keeping buffer zones around water bodies and maintaining grassed w aterways, which are essentially equivalent to lands under the CRP and the FWP.

4.2 Statistics Canada collects data on agricultural land under conservation practices through the Farm Environmental Management Survey (FEMS). Th e survey is conducted every five years after the census year and the data are c ollected for the census year. The sampling and estimation procedures for the FEMS are similar to those for annual surveys as mentioned in the previous section. Copie s of the FEMS questionnaires can be found by following the links at Statistics Canada’s website: http://www.statcan.gc.ca/cgibin/imdb/p2SV.pl?Function=displayInstrBySubTheme&th emeid=350&parentid=349&la ng=en&db=imdb&adm=8&dis=2 . So far, two FEMS have been conducted – one in 200 2 for the reference year 2001 and the other in 2007 f or the reference year 2006. The next

FEMS is scheduled for 2012.

4.3 Similar to annual crop surveys in the Canadian agriculture statistics program, samples for the FEMS are drawn from the national Farm Regis ter following a stratified sampling procedure. Stratum-specific and observation-specifi c weights are applied to the data to derive estimates. The estimates are validated by co mparing with the Census of Agriculture data and the results of other surveys, and through data validation agreements with the provincial agricultural statistics departm ents. Data quality is measured by the coefficient of variation (CV).

4.4 The data collected by FEMS include, among othe rs, information on wetlands, buffer zones around water bodies (riparian buffer 11 

### ), field shelterbelts or windbreaks and grassed waterways. Data for two types of wetlands a re collected: (i) seasonal or temporary wetlands that are often cultivated, and ( ii) permanent wetlands that are flooded year-round except for extreme drought perio ds. Seasonal wetlands are in general comparable to the eligible FWP lands, while permanent wetlands can be compared to lands under the Wetlands Reserve Progra m (WRP), which EPA did not include as part of the existing agricultural lands for the United States. Similarly, only seasonal wetlands, not permanent wetlands, are incl uded in setting the 2007 baseline acreage for Canada discussed further below. Lands i n riparian buffer, field shelterbelts

10 The Conservation Reserve Enhancement Program (CRE P) supports increased conservation practices such a s filter strips and forested buffers, development and restoration of wetlands through the planting of ap propriate groundcover etc. with project-specific environmenta l objectives.

11 In some cases, strips of riparian buffers may be planted with shrubs and trees. However, those strip s are usually less than 120 feet (or 36.6 m) wide, and th erefore, do not qualify as forestland as defined in the EPA report “Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990–2008,” which is consistent with the

definitions in the RFS2 final rule.

### 7

and grassed waterways are equivalent to the general CRP lands in the United States (see Table 2 in Appendix 1 for land comparison). None of these lands constitutes “forestland,” which are tracked and reported separa tely.

B. A reasonable identification of the aggregate amo unt of existing agricultural land in

Canada can be made.

5.0 Identification of the 2007 Baseline of Existing Agricultural Land and Trigger for Further Investigation to Determine if Baseline has been Exceeded

5.1 The following analysis of the total amount of “ existing agricultural land” 12 

### is to determine the 2007 baseline for the aggregate compl iance approach for crops and crop residues grown in Canada. The analysis applies for the whole of Canada covering all geographical regions that produce annual, perennial and horticultural crops (see Figure 1 for map).

5.2 In the final RFS2 rule dated March 26, 2010, “ existing agricultural land” has been defined as cropland, pastureland and land enrolled in the CRP that was cleared or cultivated prior to December 19, 2007, and that was nonforested and actively managed as agricultural land or fallow on that date. EPA identified three types of agricultural land eligible for inclusion in the baseline, which inclu de cropland, pastureland and CRP lands. Each of these is analyzed to support a 2007 baseline of 124 million acres of “existing agricultural land” in Canada for purposes of the RFS2.

5.3 EPA defines cropland as “land used for producti on of crops for harvest and includes cultivated cropland, such as for row crops or close -grown crops, and non-cultivated cropland, such as for horticultural or aquatic crop s.” Based on these definitions, the total cropland area, identified for purposes of the RFS2, is the sum of areas for annual, perennial and horticultural crops plus the summer fallow area.

5.4 The land area data collected through Statistics Canada’s annual crop survey for all annual, perennial and horticultural crops, except t hose for Christmas tree, sod and

nursery 13 

### , constitute an annual time series. Therefore, the land areas for Christmas tree, sod and nursery are taken from the Censuses of Agri culture and trended over the years

between the censuses. These land area data are adde d together to derive annual estimates of the total cropland area for a 16-year period from 1995 to 2010. The total cropland area including summer fallow in Canada thu s estimated stood at 99.0 million

acres in 2007.

12 “Existing agricultural land” includes cropland, pastureland and land enrolled in the CRP in the U.S. Since Canada does not have any program for conservation o f agricultural land directly comparable to the CRP, agricultural lands under conservation practices tha t are equivalent to the eligible CRP lands are incl uded in the analysis.

13 While collected annually, data on Christmas tree, nursery and sod areas have not been published each year. The data is not published if it is insufficient und er the data quality standards.

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5.5 The annual surveys mentioned in Section 3 of th is document do not collect information on land area segregated for tame or seeded pasture (pastureland) 14 

### . The census data on tame or seeded pasture acreage are therefore analyz ed for trend and the results are used to estimate the land area for tame or seeded pastur e for the years between the censuses. Based on the estimate, the total area for tame or s eeded pasture in Canada was 14.4

million acres in 2007.

5.6 The total area for cropland and pastureland in Canada in 2007, as evident in the above estimates, was 113.4 million acres. The mean of thi s total area for a 16-year period from

1995 to 2010 is 113.2 million acres with a standard deviation of 1.0 million acres. Table 3 in Appendix 1 shows the mean, standard deviation, the minimum and the maximum for the total of cropland and pastureland (data are provided in Table 5, Appendix 2).

5.7 Estimates for agricultural lands under conserv ation are obtained from the FEMS data. As noted earlier, the FEMS is conducted every five years and the last FEMS was conducted in 2007 (data were collected for 2006). 15 

### While data for 2007 is not available,

the FEMS data that are available can be used to est imate eligible lands for 2007. An analysis of the FEMS data shows that in 2006 Canadi an farms had an estimated 9.8 million acres of agricultural lands under conservat ion practices that are comparable to eligible lands under CRP and FWP in the United Stat es (Table 4, Appendix 1). The amount of agricultural lands under the same conserv ation practices in 2001 was

estimated to be 8.5 million acres. Since the area o f agricultural lands under conservation practices tended to increase between 2001 and 2006, it can be rationally assumed that the amount of agricultural lands under conservation practices in 2007 was also approximately 9.8 million acres, the estimate for 2 006, if not higher.

5.8 Based on the above estimates, the total amount of existing agricultural land in Canada for purposes of the RFS2 in 2007 was (113.4 + 9.8 = 123.2) 123.2 million acres. The baseline acreage for total eligible agricultural la nd (i.e., the sum of cropland, summer fallow, tame/seeded pasture and land under conserva tion practices) in Canada can be set

at 124 million acres. This baseline accounts for th e year-to-year fluctuations by accounting for one standard deviation 16 

### (1.0 million acres) to the total acreage of cropland, summer fallow, and tame/seeded pasture (1 13.4 million acres, as outlined in Table 3) plus 9.8 million acres of farmland in conservation prac tices (as mentioned in paragraph 5.7 and Table 4 in Appendix 1).

14 Annual crop survey data on land for pasture, whic h includes several categories of land in pasture (s uch as tame/seeded pasture and rangeland), does not segreg ate pastures by type. See Appendix 1, Table 1.

15 Data for two quinquennial periods may not be adeq uate for trending over the years. Also, the 2001 an d 2006 FEMS data are not fully comparable due to survey re design in 2006. However, estimates have been compar ed and adjustments have been made to the extent possib le.

16 In any statistical estimate, it is appropriate to include a measure of variability to account for sta tistical variations. In addition to expressing the variabili ty of the data, standard deviation is commonly used to calculate

the confidence interval of statistical estimates. I n the Canadian total agricultural land data from 19 95 to 2010, the standard deviation is very small (less than 0.9%) s uggesting a narrow band for the confidence interval estimates over the 16-year period. This also indicates that t he overall trend of agricultural land use in Canada is stable with very low year-to-year fluctuations.

### 9

5.9 As explained above and further described below, the above quantification of cropland, pastureland, and lands under conservation practices from survey and census data of Statistics Canada represents a reasonable assessmen t of the total agricultural land area in Canada available for the production of crops and cr op residues that satisfy EPA’s definition of renewable biomass and existing agricu ltural land. The proposed baseline acreage also meets the statutory requirement that t he land had been cleared or cultivated and actively-managed or fallowed prior to December 19, 2007. The data used in the analysis and quantification are as credible, reliab le and verifiable as the USDA data used by EPA to determine the amount of U.S. agricul tural land.

5.10 The aggregate compliance determination mechani sm for the United States calls for

action if EPA finds that the total land in use for the production of crops, including crops for grazing and forage, is greater than 397 million acres (i.e. within 5 million acres of EPA’s established 402 million acre baseline). In su ch cases, EPA will conduct investigations to evaluate the presumption for the aggregate compliance approach. If EPA finds that the 2007 aggregate baseline acreage has been exceeded, EPA will publish a finding to that effect in the Federal Reg ister and additional requirements will be triggered for renewable fuel producers. A simila r mechanism for compliance determination can be identified and applied for Can ada as well.

5.11 Similar to EPA’s approach for the United State s, it is proposed that if the acreage of the total land in use for the production of crops in Ca nada, including crops for grazing and forage, is greater than 122 million acres (i.e., wi thin 2 million acres of the 124 million acres baseline), then EPA and Statistics Canada wil l launch an investigation to evaluate the presumption regarding the aggregate compliance approach for Canada. It is further proposed that if EPA, in consultation with Statisti cs Canada, finds that the 2007 baseline area of land (i.e., 124 million acres) has been exc eeded, then the Agency will notify Agriculture and Agri-Food Canada (AAFC) of its find ing and enter into discussions with AAFC prior to publication of the findings in t he Federal Register.

C. Land use trends before 2007 and after support ap plication of an aggregate compliance approach for Canada.

6.0 The Overall Trend of Agricultural Land Use in C anada has been Stable Since 1991

6.1 According to the Canadian Census of Agricultur e data, the acreage of cropland and summer fallow plus the acreage of seeded pasture in Canada has been stable since 1991 with an overall downward trend (Figure 2, Appendix 1). The results of an analysis using the relevant annual survey data from 1995 to 2010 ( Table 3 and Figure 3, Appendix 1)

corroborate the census results. As evident in Table 3, the acreage of cropland and summer fallow plus the acreage of seeded pasture in Canada has trended downward

since 1995 with a mean value of 113.2 million acres and a standard deviation of 1.0 million acres. The average intensity of farming (ac res of lands in crops as a percent of acreage in farmland) during the period has been 67. 5%. The Census of Agriculture data

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from 1991 to 2006 produce similar statistics (112.5 million acres on average plus an estimated average of 2.1 million acres for land are a undercoverage, with a standard deviation of 1.2 and a cropping intensity of 67.2%)

.

6.2 From 1995 to 2010, the peak acreage of agricul tural land that would be eligible as cropland and pastureland, as defined by EPA, was ap proximately 115.2 million acres in 2000. In 2007, the acreage was approximately 113.4 million acres, which remained unchanged in 2008 and 2009. In 2010, the acreage ha s decreased to 112.7 million acres. It may be mentioned here that the above numbers do not include the areas for cropland under conservation practices and idle cropland. The underlying Statistics Canada data along with notes on their sources are provided in T able 5 (Appendix 2).

6.3 As with the United States, 17 

### there have been some year-to-year fluctuations in the total agricultural land, but the trend (slightly downward ) has been fairly constant (Figure 3, Appendix 1). Two important recent trends are notice able in the Canadian Census of Agriculture data. Since 1991, the acreage of seeded pasture is increasing while the acreage for crops and summer fallow is declining. T he overall trend of the total agricultural land is not affected as the increase i n seeded pasture area is offset by a decrease in crops and summer fallow area. As furthe r described below, this trend is largely due to changes in farming practices that in crease yields, eliminating the need for new cropland, and that increase sustainable farming practices, such as increased use of rotational crops (e.g., rotating canola with wheat)

.

D. Historical land use, agricultural practices, e conomic considerations, legal constraints and other factors showing that producers of the feedsto cks will likely continue to use existing agricultural land.

7.0 Producers will continue to Use Land within Iden tified Agricultural Land Area

7.1 EPA has used a lifecycle analysis to determine that there will be little need for new

lands in the United States to meet the increased vo lumes of renewable fuel that will be produced under the RFS2. In that analysis, EPA has found little contribution of biofuels from Canada, and mentioned that any imports of biof uels into the United States for the RFS2 program would likely come from Brazil. 18 

### More importantly, EPA’s modeling from the Regulatory Impact Analysis for the RFS2 Ru le using FAPRI-CARD 19 

### shows little to no harvested crop area changes in Canada for the fuels analyzed. 20 

### Another

17 Natural Trends Agricultural Lands (EPA-HQ-OAR-200 5-0161-3057).

18 RFS2 Regulatory Impact Analysis, p.164. EPA noted that “trace” amounts of ethanol have entered the U nited States from Canada, Id. at p.162. EPA has identified several cellulosic de monstration plants in Canada in the Regulatory Impact Analysis for the RFS2 Rule. Id. at pp.173-80.

19 Food and Agricultural Policy and Research Institut e international models, as maintained by the Center for Agricultural and Rural Development (FAPRI–CARD), Io wa State University.

20 RFS2 RIA, at §2.4.4.2.2. While EPA’s lifecycle ana lysis can provide support for EPA’s choice of an aggregate compliance approach, it should be noted t hat FAPRI/CARD recognizes that the magnitude of lan d use changes from biofuels is uncertain and largely unat tributable. See Presentation of Bruce Babcock, Center for

### 11

analysis of land use impacts of the RFS2 has shown that changes in land areas in

Canada are not associated with increased biofuel de mand in the United States. 21



### 7.2 There are two forces at work that will allow f or ample production of biofuels in Canada without the need to cultivate new land. Again, thes e are similar to the situation in the United States that was examined for the purposes of determining if the aggregate analysis approach was appropriate.

7.3 The first force at work is the long term trend towards reduction of summer fallow in Canada. Summer fallow along with the accompanying t illage has not contributed to soil conservation and improved soil quality. Over the pa st 30 years, a concerted effort aimed at continuous cropping coupled with conservation or zero tillage has moved more and

more acres out of summer fallow and into sustainabl e production. In 1995, there were about 16.8 million acres of summer fallow. This fig ure has been reduced almost steadily over the years to reach 6.2 million acres in 2009, which is about a third of what it was in 1995. In 2010, however, many prairie farmers could not seed their croplands because of unfavorable weather conditions, and consequently, t he summer fallow acreage in 2010

has increased to 11.6 million acres. All of these s ummer fallow acres could be converted to sustainable production with proper crop rotation s over time.

7.4 The second force at work in aid of additional production of biofuels is the advent of biotechnology. The introduction of genetically engi neered varieties has contributed to increased yields in the medium term. For example, a verage yields of canola – one of the major crops used in the biofuel industry – have inc reased by 46% since the early 1990s. All of this growth in yield has been realized since 1996, the year genetically engineered varieties were first commercially introduced. More recent breakthroughs in the technology will drive crop yields up further and th e increases in yield will help provide

biofuels without additional stress on Canada’s land base.

7.5 New agricultural land is not expected to be bro ught into production in order to fulfill

Canada’s federal biofuels mandate. The results of t he Regulatory Impact Analysis conducted for Canada’s biofuels mandate, as require d by the Canadian Environmental Protection Act, reveal no significant changes in la nd use. 22 

### This mandate is expected to be met with increased domestic production from the existing land base achieved through changes in cropping practices and productivity gain s described above, as well as imports mainly from the United States. In addition, a numbe r of Canadian provinces already have biofuel mandates in place, which have not had any noticeable impact on agricultural land use in Canada.

Agricultural and Rural Development, Iowa State Univ ersity Presentation, The CARD/FAPRI Modeling System

and Indirect Land Use , Nov. 2009, available at: http://rsb.epfl.ch/page-42475.html

.

21 Thomas L. Darlington, Air Improvement Resource, I nc., Land Use Effects of U.S. Corn-Based Ethanol , at p.31 (Feb. 24, 2009), available at: http://www.etha nolrfa.org/pages/reports-and-studies

.

22 The Regulatory Impact Analysis Statement for Canada ’s federal biofuels mandate can be accessed at: http://www.gazette.gc.ca/rp-pr/p1/2010/2010-04-10/h tml/reg1-eng.html.

### 12

7.6 As in the United States, existing economic and market factors in Canada favor sustainable agricultural practices, increasing crop yields and more efficient use of existing land rather than converting non-agricultur al land to crop production. Falling net returns from crops, rising net returns from timber along with an accelerated expansion

of urban areas leave no incentive for farmers to br ing non-agricultural land in crop production. 23 

### Farmers rather rely on yield-enhancing technologie s which often come hand-in-hand with sustainable cropping practices. Federal and provincial government policies also promote sustainable agricultural prac tices.

7.7 Almost all of Canada’s agricultural lands are in the southern part of the country and away from the major forestland. Because of weather, geographic and geological factors, there is virtually no incentive to convert non-agri cultural and forest lands in the country to agricultural land. Moreover, the vast majority of Canada’s forestland (over 90%) is under governmental control, and Canada has strong n ational and provincial policies against deforestation. Since 1990, Canada has had no significant change in forest cover.

7.8 The vast majority of land in Canada has signif icant limitations that restrict the ability of the land to be used for agricultural purposes; “Onl y about 5 percent of [Canadian] land is free from severe constraints on crop production. ” 24 

### The limitations on agricultural production include climate and soil quality. The va st majority of forestland in Canada is in areas where the climate restricts the length of growing season, making it infeasible and uneconomic to cultivate crops.

E. Annual tracking of Canadian agricultural lands w ith Statistics Canada and AAFC.

8.0 Plan to Provide EPA Data and Analysis for Annu al Evaluation

8.1 The Agriculture Division of Statistics Canada, in collaboration with AAFC, will conduct data compilation and analysis necessary to assist EPA in its annual assessment of the aggregate compliance approach. Statistics Ca nada is the official source for data and estimates of agricultural land in Canada. Stati stics Canada’s Agriculture Division has been conducting censuses of agriculture and sur veys since the agency’s inception, and earned a reputation in collecting, analyzing an d disseminating credible, reliable and verifiable information on agricultural production, land use and agri-environmental factors. A good number of agricultural survey progr ams of Statistics Canada are conducted with the support from the federal agricul ture department, Agriculture and Agri-Food Canada (AAFC).

23 Lubowski, R.N., A.J. Plantinga and R.N. Stavins, 2 007. What Drives Land-Use Change in the United Stat es? A National Analysis of Landowner Decisions. Nationa l Bureau of Economic Research (NBER) Working Paper No. W13572, November 2007. The first author is from USDA Economic Research Service, the second author from Oregon State University and the third author i s from Harvard University.

24 Statistics Canada, Urban Consumption of Agricultural Land , Rural and Small Town Canada Analysis Bulletin, Vol. 3, No. 2 (Sept. 2001), available at: http://www.statcan.gc.ca/pub/21-006-x/21-006-x20010 02-eng.pdf.

### 13

8.2 The Agriculture Division of Statistics Canada publishes its September crop survey report containing land area estimates (preliminary) for field crops and summer fallow during the first week of October each year 25 

### . While data on hay and forage are collected in the September crop survey, the estimates for hay and forage are not published until the first week of December with the final crop surv ey report. As EPA will require land area estimates well ahead of November 30 each year, arrangements will be made to analyze and publish the preliminary data on hay and forage by the fourth week of October. Data on land areas for greenhouse, sod, nu rsery, fruits and vegetables, which constitute less than 1% of the total cropland, are published during the middle of the following year.

8.3 To provide EPA with sufficient data to make a d etermination regarding the compliance of the baseline for Canada by November 30 each year , the Agriculture Division of Statistics Canada will provide EPA current year’s p reliminary data 26 

### on land areas for field crops and summer fallow, and an approximate a rea for hay and forage based on past years’ data in the second week of October each year. The immediate past year’s land area data on greenhouse, sod, nursery, fruits and vegetables will be provided at the same time from the respective annual survey results . It is pertinent to note that over the last 16 years the land areas for greenhouse, sod, n ursery, fruits and vegetables have not undergone any significant changes. An estimated lan d area data for tame or seeded pasture for the year, obtained from the trend in th e relevant census data, will also be provided to EPA for its annual assessment. Current year’s preliminary data on hay and forage will be provided in the fourth week of Octob er each year. Data for submission to the EPA will be compiled in a spreadsheet that will include notes on their sources and methods of derivation. The data file along with a r eport containing relevant analysis and justifications wherever necessary will be sent elec tronically to the EPA.

8.4 It should be noted that Statistics Canada is t he agency required to provide data on land

use in Canada and other issues to international bod ies (e.g., climate change data to the United Nations, production data to FAO and OECD). S tatistics Canada is legislated under the Statistics Act to provide data for the wh ole of Canada and each sector of the economy, including agriculture. Its data are fully transparent within the limits set by the Statistics Act, the Privacy Act and the Access to I nformation Act. The agency publishes

and maintains extensive historical data on various aspects of Canadian agriculture.

25 The final (post-harvest) crop survey report contai ning data on land areas for field crops, hay and fo rage, and summer fallow is published during the first week of December each year.

26 Preliminary data are subject to revisions until th e final estimates for the year is published in Dece mber. In the past five years (2006 to 2010), the variation betwe en preliminary and final estimates remained within +/– 0.5%.

### 14 Appendix 1

Table 1: Comparison of Components of Agricultural L and

Component US Census of Agriculture 2007

definition* Canada Census of Agriculture 2006
definition*

Cropland Section 2, Items 1a and 1b: Includes

field crops, hay and forage, vegetables, potatoes, melons, fruits, nursery, floriculture, sod, mushrooms, vegetable seeds, greenhouse, Christmas trees, short rotation woody crops, and other

crops. Does not include Christmas tree (about 0.1 million acres) and short rotation woody crops, which are reported separately. The rest of the items are identical ( Questions in Steps* 9, 11, 12 and 13 of the 2006 Census of Agriculture questionnaire)

Summer fallow
land Section 2, Item 1c: Includes summer

fallow or chemical fallow. It may have been only treated with herbicides, only tilled, or a combination of these practices to control weeds and
conserve moisture and not seeded. Equivalent to the definition of

“ Summerfallow ” ( Step 14, Question

102 ).

Cropland idle /
used for cover crops or soil improvement

(not harvested, not pastured / grazed) Section 2, Item 1d: Includes land used

for cover crops or soil improvement, but not harvested or grazed; land in CRP, WRP, FWP, CREP* or other Federal or State conservation programs that was not hayed or grazed in 2007, or planted to trees for future harvest; land occupied with growing crops for harvest in 2008 or later years but not harvested or summer fallowed in 2007; and land in “skipped” rows between rows of crops or field strips should be reported here if the land was not used for any other

purpose. There is no CRP equivalent in Canada. However, Statistics Canada collects binary (yes or no, not area) data on cover crops, buffer zones around
water bodies and windbreaks /
shelterbelts practices ( Step 20,
Question 118 ). Land utilized in those practices is mostly equivalent to the US
CRP land. Wetlands in “ Woodlands
and wetlands ” category ( Step 14,
Question 105 ) are equivalent to lands under the WRP. Idle cropland is
included in the “ All other land” category ( Step 14, Question 106 ).

Permanent pasture Section 2, Item 2a: Includes

pastureland and rangeland, other than woodland pasture or cropland, normally used for pasture or grazing. It usually includes land referred to as meadow, prairie, or range and consists of various types of grasses, such as bunch grass, shortgrass, buffalo grass, bluestem, bluegrass, switch grass, etc. Equivalent to the definition of “ Natural land for pasture ” ( Step 14, Question
104 ).

Woodland pastured Section 2, Item 2b: Includes woodland

or timber tracts, natural or planted, used for pasture or grazing. Included in “ Natural land for pasture ” ( Step 14, Question 104 ).

Continued to next page...

### 15 Appendix 1

Table 1: Continued from the previous page

Component US Census of Agriculture 2007

definition* Canada Census of Agriculture 2006
definition*

Cropland used only for pasture or grazing Section 2, Item 2c: Includes land

pastured or grazed which could have been used for crops without any additional improvements (e.g., rock removal, terracing, tree removal, etc.); and land in planted crops that was hogged-off, pastured, or grazed and not harvested for grain or hay. Equivalent to “ Tame or seeded pasture ” ( Step 14, Question 103 ).

Woodland not pastured Section 2, Item 3: Includes cut over

and deforested land with new or remaining growth that has future value as wood products and was not pastured in 2007; and all other woodland, including tapped maple trees (sugar bush). Partially matches the definition of

“ Woodlands and wetlands ”, so far as it includes woodlots and sugarbush. It also includes windbreaks, bush, ponds, bogs, marshes, sloughs, etc. ( Step 14,
Question 105 ).

All other land Section 2, Item 4: Include all other land

occupied by buildings, farmsteads, windbreaks, lanes, roads, ponds, barn lots, gardens for home use, wasteland, etc. Also, include all land in this operation that does not fit the definition of the other land use categories listed in items 1, 2, and 3. Do not include windbreaks and ponds.
Idle land and land for greenhouses
and mushroom houses are included in this component ( Step 14, Question

106 ).



### * Section and item numbers in the second column refer to the contents of the U.S. Census of Agriculture Questionnaire 2007, and the definitions are taken from the 2007 Census of Agriculture Report Form Guide of the USDA.

Step and question numbers in the third column refer to the contents of the Canadian Census of Agriculture Questionnaire 2006, and the definitions are based on the descriptions/instructions provided in the questionnaire.

CRP = Conservation Reserve Program WRP = Wetlands Reserve Program FWP = Farmable Wetlands Program CREP = Conservation Reserve Enhancement Program

### 16 Appendix 1

Table 2: Comparison of Farmland under Conservation Programs and Practices

Category US Program definition* Canadian environmental management practices
definition*

Farmable
Wetlands Farmable Wetlands Program (FWP): To be eligible, land

must be either:

Farmed and prior converted wetland that was cultiva ted 3 of the 10 most recent crop years, and is physically an d legally capable of being cultivated; or

A constructed wetland developed to receive flow for a drainage system for the purpose of providing nitrog en removal and other functions; or

Devoted to commercial pond-raised aquaculture in an y year during 2002-2007; or

Land that was cropped during 3 of 10 crop years bet ween 1990 and 2002, and was subject to the natural overf low of a prairie wetland. Seasonal wetlands normally have water present until mid summer or early fall, and during most years.

They include ponds, sloughs, potholes, seasonally flooded meadows, marshes and treed wet swamps, and exclude permanent
wetlands that are flooded yearround except for extreme drought periods. Seasonal wetlands are often cultivated and forage seeds are sown especially in drier springs (Figures 4 and 5; Appendix 2). 27

Land under
Conservation

Practices Conservation Reserve Program (CRP): To be eligible, land

must be either:

Cropland with a recent cropping history, and which is physically and legally capable of being planted in a normal manner to an agricultural commodity; or

Certain marginal pastureland that is suitable for u se as a riparian buffer or for similar water quality purpos es.
FSA uses the following Environmental Benefits Index (EBI)
factors to assess the environmental benefits for th e land
offered:

• Wildlife habitat benefits resulting from covers on contract

acreage;

• Water quality benefits from reduced erosion, runoff , and leaching;

• On-farm benefits from reduced erosion;

• Benefits that will likely endure beyond the contrac t period;

• Air quality benefits from reduced wind erosion; and

• Cost. Riparian buffer zones are strips of natural or planted vegetation that border wetlands, streams and rivers. They protect wildlife by providing habitats and water quality by capturing sediments and
runoffs.

Field shelterbelts (or
windbreaks ) include plantation usually made up of 1 to 3 rows of trees or shrubs planted to reduce the impact of wind on crops and to protect soil from erosion.

Grassed waterways are broad and shallow channels designed to
move surface water across farmland without causing soil erosion. The vegetative cover slows water flow and protects the
channel surface from erosion.

* Definitions of lands eligible for FWP and CRP ar e taken from the relevant FSA webpages at: http://www.fsa.usda.gov/FSA/webapp?area=home&subje ct=copr&topic=fwp http://www.fsa.usda.gov/FSA/webapp?area=home&subje ct=copr&topic=crp

Canadian definitions of wetlands are taken from the 2006 Farm Environmental Management Survey questionnaire. Definitions of riparian buffer, fiel d shelterbelts and grassed waterways are taken from the relevant websites of AAFC and Ontario Ministry of A griculture, Food and Rural Affairs at: http://www4.agr.gc.ca/AAFC-AAC/display-afficher.do? id=1235756863870&lang=eng http://www4.agr.gc.ca/AAFC-AAC/display-afficher.do? id=1192556664605&lang=eng http://www4.agr.gc.ca/AAFC-AAC/display-afficher.do? id=1197485172103&lang=eng http://www.omafra.gov.on.ca/english/engineer/facts/ 09-021.htm

27 Huel, D., 2000. Managing Saskatchewan Wetlands – A Landowner‘s Guide (p. 20). Saskatchewan Wetland Conservation Corporation, Regina, Saskatchewan, Can ada. Available online at: http://www.swa.ca/Publications /Documents/ManagingSaskatchewanWetlands.pdf17Appendix 1Figure 1: Map of Canada Showing Agricultural Land in 2007Provincial boundary2006 Census of Agriculture Ecumene2007 Agricultural land based on satellite dataNote: Agriculture ecumene refers to areas where agriculture activity is sufficiently concentrated.Source: Advanced Very High Resolution Radiometer (AVHRR) satellite imagery at 1-kilometer resolution,and the 2006 Census of Agriculture ecumene boundaryfile.

### 18 Appendix 1

Table 3: Total Cropland and Pastureland 28 in Canada, 1995 to 2010

Range

Cropland +
Summer
fallow Seeded

Pasture Total

Cropland
and
Pastureland Minimum Maximum Year

Million of Acres

1995 103.7 10.9 114.6 114.2 115.0

1996 101.8 10.7 112.6 112.5 115.1

1997 101.8 11.0 112.8 112.7 112.9

1998 102.5 11.2 113.7 113.5 113.9

1999 103.1 11.5 114.6 114.3 114.9

2000 103.4 11.7 115.2 114.8 115.6

2001 101.9 11.9 113.8 113.4 115.9

2002 100.6 12.2 112.8 112.7 112.9

2003 100.2 12.5 112.7 112.4 112.9

2004 99.6 12.8 112.4 112.0 112.8

2005 98.7 13.1 111.8 111.3 112.3

2006 97.9 14.1 112.0 111.5 113.0

2007 99.0 14.4 113.4 113.3 113.5

2008 98.7 14.7 113.4 113.1 113.6

2009 98.4 15.0 113.4 113.0 113.8

2010 97.4 15.3 112.7 112.4 112.9

Mean 100.5 12.7 113.2 112.9 113.8

Standard
deviation 2.1 1.6 1.0 1.0 1.1

Notes:

1. Crops and summer fallow acreages have been calcu lated as the sum of seeded area and summer fallow area as published by statistics Canada on th e CANSIM (see Table 5 in Appendix 2 for details).

2. The seeded pasture acreages for the census years (years ending in 1 and 6) are taken from the Census of Agriculture seeded pasture area data and those for the other years have been derived
from the trend in Census data between 1986 and 2006

. 3. In computing ranges for the census years, the un dercoverage rates have been used. The ranges for other years are based on a 95% confidence inter val.

28 Not including farmland in conservation practices ( Table 4) and idle cropland.

### 19 Appendix 1

Table 4: Agricultural Land under Conservation Pract ices in Canada, 2001 and 2006

2001 2006 Conservation Practices Million of acres

Seasonal Wetlands 2.2 2.7

Land in Riparian Buffer 3.4 4.1

Land in Shelterbelts or Windbreaks 2.3 2.4

Grassed Waterways 0.5 0.6

Total land in conservation practices 8.5 9.8

Notes:

1. For 2001 estimates, farmstead shelterbelts or windb reaks have been added to field windbreaks or shelterbelts to compensate for under-reporting of w indbreaks and shelterbelts due to differences in the wording and the placement of the relevant qu estions of the 2001 Farm Environmental Management Survey questionnaire.

2. The riparian buffer areas for 2001 and 2006 are der ived by comparing and using estimated
dimensions from both 2001 and 2006 Farm Environment al Management Surveys (FEMS). The differences between the survey estimates that could have resulted from the variations in survey questionnaires relating to riparian buffer areas we re minimized in this approach.

Source: Statistics Canada, Farm Environmental Management S urvey, 2001 and 2006.

### 20 Appendix 1

Figure 2: Quinquennial Trend of Agricultural Land U se, Canada, 1991 to 2006

Quinquennial Trend of Agricultural Land Use, Canada

112.6 112.5 113.4 111.5



### y = -0.25x + 113.12

100 105 110 115 120

1991 1996 2001 2006 Million acres

Crops + Summerfallow + Seeded pasture Linear (Crops + Summerfallow + Seeded pasture)

Notes: The land area for undercoverage has not been accoun ted for in the analysis. A negative trend is indicated by the coefficient of x in the equation (– 0.25).
Source: Statistics Canada, Censuses of Agriculture, 1991, 1996, 2001 and 2006.

Figure 3: Annual Trend of Agricultural Land Use, Ca nada, 1995 to 2010

Annual Trend of Agricultural Land Use, Canada



### y = -0.08x + 113.90

100 105 110 115 120

1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 200 7 2008 2009 2010 Million acres

Crops + Summerfallow + Seeded pasture Linear (Crops + Summerfallow + Seeded pasture)

Note: A negative trend is indicated by the coefficient of x in the equation (– 0.08).
Source: Statistics Canada, Annual surveys from 1995 to 201 0 and Censuses of Agriculture, 1996,

2001 and 2006.

### 21 Appendix 2

Table 5: Components of Agricultural Land Use, Canad a, 1995 to 2010

Field crops
and Specialty

crops Hay and

Forage Summer

fallow Fruits and

Vegetables Nursery,

Sod and
Christmas

tree Seeded

pasture Total

Cropland
and
Pasture (Annual Surveys) Total

Cropland
and
Pasture (Census +

undercoverage) Years

Million of Acres

1995 69.5 16.7 16.8 0.5 0.2 10.9 114.6 --

1996 69.5 16.3 15.3 0.5 0.2 10.7 112.6 115.1

1997 70.9 16.2 14.0 0.5 0.2 11.0 112.8 --

1998 71.6 16.8 13.4 0.5 0.2 11.2 113.7 --

1999 69.9 17.6 14.9 0.5 0.2 11.5 114.6 --

2000 72.7 18.5 11.5 0.5 0.2 11.7 115.2 --

2001 70.1 19.5 11.6 0.5 0.2 11.9 113.8 115.9

2002 69.9 19.8 10.2 0.5 0.2 12.2 112.8 --

2003 70.8 20.0 8.6 0.5 0.2 12.5 112.7 --

2004 69.9 20.4 8.6 0.5 0.2 12.8 112.4 --

2005 67.9 20.7 9.3 0.5 0.2 13.1 111.8 --

2006 67.6 21.0 8.6 0.5 0.2 14.1 112.0 113.0

2007 70.0 21.0 7.3 0.6 0.2 14.4 113.4 --

2008 71.0 20.9 6.0 0.5 0.2 14.7 113.4 --

2009 70.5 21.0 6.2 0.6 0.2 15.0 113.4 --

2010 64.3 20.8 11.6 0.5 0.2 15.3 112.7 --

Mean 69.8 19.2 10.9 0.5 0.2 12.7 113.2
-- Standard

deviation 1.9 1.9 3.3 0.0 0.0 1.6 1.0 --

Percent of
the mean 61.6 17.0 9.6 0.5 0.2 11.2 100.0 --

Notes:

1. Field crop and specialty crop area data are obta ined from Statistics Canada’s CANSIM Tables 001- 0014, 001-0017, 001-0018, 001-0019, and 001-0020.

2. Data on areas in fruits and vegetables are taken from Statistics Canada’s CANSIM Tables 001-0009 and 001-0013, and the publication series “Fruit and Vegetable Production”. Available at: http://www.statcan.gc.ca/bsolc/olc-ce l/olc-cel?catno=22-003-X&chropg=1&lang=eng.

3. Data on summer fallow land are obtained from Sta tistics Canada’s CANSIM Table 001-0017.

4. Data for hay and forage acreage are obtained fro m Statistics Canada’s CANSIM Table 001-0018.

5. Data on acreages of seeded pasture, nursery, sod and Christmas tree are taken from the Census of Agriculture for the census years (years ending in 1 and 6), and those for the other years have been
derived from the trend in the Census data between 1 986 and 2006.

6. Census of Agriculture land use data are obtained from http://www.statcan.gc.ca/pub/95-632- x/2007000/t/4185579-eng.htm and the undercoverage r ates were taken from the data quality reports.

### 22 Appendix 2

Figure 4: Satellite Images of Seasonal Wetlands, Ma nitoba, Canada

Fannystelle Area, 55 km SW of Winnipeg, Manitoba

June 2003 (below average precipitation)
The entire section in yellow box was cropped June 2005 (above average precipitation) Only part of the section was cropped

June 2003 (below average precipitation)
The area in yellow box was cropped June 2005 (above average precipitation)
The area in yellow box was not cropped

Source: Landsat-5 satellite imagery at 30m resolution.

### 23 Appendix 2

Figure 5: Satellite Images of Temporary Wetlands, S askatchewan, Canada

Corinne Area, 40 km S of Regina, Saskatchewan

June 2008 (average precipitation)
Almost 100% of the sections was cropped June 2010 (above average precipitation)
Temporary wetlands created by rainfall

Quill Lake Area, 150 km E of Saskatoon, Saskatchewa n
June 2008 (average precipitation) Smaller black spots are temporary wetlands June 2010 (above average precipitation)
Bigger black spots are more abundant

Source: Landsat-5 satellite imagery at 30m resolution.