Dear Sir or Madam,
we thank you for having the opportunity to contribute to your online consultation on the voluntary guidelines for sustainable soil management.
Here are our comments and suggestions:
It would be very helpful to specify the stakeholders to which the guidelines will be addressed. To address governments and other institutions will not be sufficient in our opinion.
We think that it is necessary and important to identify and adress multipliers which are close to farmers and farmers associations, e.g. food business, food standards, consumer organisations, environmental NGOs.
3.2 Non-tillage and conservation agriculture is mentioned as a good practice with multiple environmental benefits. It shoul be added this practice is only sustainable if it is combined with other practices, especially cover crops and longterm crop rotation. If not, non tillage can lead to a massive use of herbicides and fungicides.
3.4 It should be clearly stated that a nitrogen balance should be the decision tool to ensure an appropriate nutrient management. Farmers should at least try a rough approximation to its calculation based on realistic yields and baseline information on the crop.
3.5 We recommend to include appropriate training for using pesticides. Also that soil disinfection shall be banned (and alternative solutions used such as diverse and long rotation).
3.7. We recommend to include a comment for enhancing the use of decision-support tools for better irrigation (tensiometers, software, etc.).
4.0 We don`t understand the use of the term “Sustainable Intensification” and recommend to better use a term like e.g. “ “efficient management for better yields”.
Furthermore we recommend to include the following aspects into the guidelines:
- recommendations for governments to deliver to multipliers soil maps as a basis for agricultural decision
- recommendation for having records of soil operations, as a training methodology for continuous improvement
- recommendation on regular soil analysis as a baseline for decision-making in terms of fertilization (farm-gate-balance)
- promoting the use of legumes for cover crops, crop rotations, winter crops, catch crops, intercrops, etc.
- continuous training for understanding agricultural soils
Kind regards
Patrick Trötschler
Bodensee-Stiftung
Dipl.-Ing. agr. Patrick Trötschler
stellv. Geschäftsführer
Fritz-Reichle-Ring 4
Patrick Trötschler