International Fertilizer Development Center (IFDC)
United States of America
Dear Ronald and all,
Thank you for the quick feedback to my original comments. Please review the text below as a matter of response to your question: do you have any other suggestions? In reference to my comment of including the supply side of fertilizer industry in the CoCoFe.
Although I do appreciate the intent of the CoCoFe consultation facilitators to focus only on the use of fertilizer, I want to politely re-emphasize on the need to include the supply and demand side of the fertilizer industry, while supporting the point of view from other panelists who have also seen the need to make CoCoFe holistic by including the supply side of the industry.
To focus only on the use of fertilizer to minimize the negative externalities related to the environment and human health, is to ignore the negative externalities on the environment and human health of the supply side of the fertilizer industry and give a “clean bill of health” to the production and manufacturing processes while placing all potential regulatory burden that would emanate from CoCoFe, on the use of fertilizer. I do understand and can also appreciate the implications with the industry by addressing those issues in CoCoFe and I can also appreciate the ease of addressing such issues from the user perspective only; but the fact is, that there is a lot the industry can still do to help reduce and therefore minimize such externalities through improvements in the production and manufacturing processes. We know that many of the negative environmental and health hazards from the use of fertilizer have their roots in fertilizer production and manufacturing processes. Focusing on the use (demand) of fertilizer will help reduce such externalities, but having a holistic approach (which entails considering also the supply side of fertilizer), will definitely minimize them.
Therefore if we are to keep as part of the CoCoFe objectives, “to minimize environmental and health impacts from pollutants such as heavy metals in fertilizers”, we need to start at and focus also on the supply side of the industry for an effective minimization of environmental contamination and human health hazards by improving the production and manufacturing processes to reduce or eliminate contaminants (i.e., heavy metals) in fertilizers and perhaps by investing in developing more efficient fertilizer (a new generation of “smart” fertilizer products congruent with crop genetics technological advances); complemented with a more efficient use of fertilizer.
However, if the facilitators of this consultation insist on the CoCoFe focusing only on the use or demand side of fertilizer, I suggest to eliminate the rhetoric of “minimizing environmental contamination and health hazard from the use of fertilizer”, and keep this as an implicit, not explicit objective. Having said that, I suggest to consider the following objectives:
1. Increase food production to supply the increasing needs of more and safer food;
2. Maximize the efficient use of nutrients fertilizer to enhance sustainable agriculture production;
3. Minimize nutrients losses to the environment (GHG, runoff and leaching into surface water streams and underground waters) to reduce contamination and human health hazard.
Less and more clear objectives, will help simplify the elaboration the CoCoFe and perhaps facilitate its vulgarization.
I believe the rest of the points raised in my original comment, still applies.
International Fertilizer Development Center (IFDC)
United States of America
Please see my contribution to the CoCoFe consultation below, in the forms of response to the quesions posted on the original note above.
Thanks.
Given the global scope of the CoCoFe, do you think the objectives are appropriate? If not, how would you add to them or modify them?
In order to make a better judgment on whether the proposed objectives are appropriate, it is necessary to have a clarity on what the goal of the CoCoFe is. A goal can be defined as a broad, general, tangible, and descriptive statement.
With this definition in mind, I can presume that the CoCoFe goal, is “to promote the responsible and judicious use of fertilizers”. If this is the goal of CoCoFe, it seems to be narrowly focused on the use (demand side) of fertilizer, while the stated objectives, specially 3 and 4, related to environmental and health impact, have also mining, production and processing implications; also, 4 is directly related to fertilizer production and beneficiation. The CoCoFe “goal” as stated, with the “aim of assisting member countries design policies and regulatory frameworks for the sustainable use of fertilizers”, would place the regulatory burden on the use (demand side) of fertilizer while neglecting the negative externalities resulting from mining, production and other activities along the supply and value chain, reflected on environmental contamination and negative impact on human health.
Consequently, I suggest to make a small change to the CoCoFe goal to be stated as: “to promote the responsible and judicious supply and use of fertilizers” where supply embraces the activities of [domestic] production (including mining), processing, blending and all other value added activities along the supply chain; and, demand would include the needs of fertilizer or nutrient sources as feedstock at each stage of the value chain, perhaps emphasizing on the last stage of the supply-demand chains: the agricultural producer/farmer as final user of fertilizer.
Based on the proposed CoCoFe goal of “promoting the responsible and judicious supply and use of fertilizers”, the underlying objectives could be:
maintaining a sustainable and environmentally friendly [domestic] fertilizer industry to supply increasing needs of global agriculture to produce more and safe food;
Increasing the efficient beneficiation of fertilizer nutrient sources (i.e., phosphate rock, potash(?)) and improve production processes to reduce the negative environmental externalities and improve the quality of fertilizer products;
maximizing the efficient use of nutrients fertilizer to enhance sustainable agriculture production;
minimizing the effect of nutrients losses via volatilization to the atmosphere (greenhouse gas emissions), runoff and leaching into surface water streams and underground waters, with negative human health and environmental consequences;
minimizing the human health hazard related to pollutants and heavy metals in fertilizers, to improve food safety;
Alternatively, these objectives could be narrowed down to 3, as follows:
Maintaining a sustainable and environmentally friendly [domestic] fertilizer industry to supply the increasing needs of global agriculture to produce more and safe food.
maximizing the efficient beneficiation of fertilizer nutrient sources (phosphoric rock and potash(?)) and improve production processes while minimizing the negative externalities related to environmental contamination and eliminating pollutants such as heavy metals to improve fertilizers quality;
maximizing the efficient use of nutrients fertilizer to enhance sustainable agriculture production while minimizing nutrients losses via volatilization to the atmosphere (greenhouse gas emissions), runoff and leaching into surface water streams and underground waters with negative human health and environmental consequences;
How should be the CoCoFe be structured to have the maximum positive impact?
CoCoFe should be structure in strata according to the different stages of production, supply and demand of fertilizer. Although this stratification can vary from country to country, it is possible to identify a generic supply-demand chain, from production to consumption, which would be applicable to almost any country. The stratification would resemble a cone, starting with general to specifics codes, where the codes of the top strata in the “cone” are applicable to the stratum below. Depending on how a country supply-demand chain is structured, the CoCoFe could start being applied at any strata below the top on the “cone”.
For example, the first stratum of CoCoFe could focus on the production of fertilizer, applicable to those countries with endowed resources to produce fertilizer (natural gas for producing nitrogen based fertilizer, phosphate rock and potash mines). Another stratum could be elaborated to be applicable to the transformation/processing fertilizer industry including blending. Successive strata can be importers, blenders, wholesalers, retailers and consumer or farmers.
On the same talking, for the current consultation to “better mold the future of fertilizer use globally”, must also include the different strata, perhaps in a simultaneous but separate consultation to make the CoCoFe more relevant and effective, otherwise it run the risk of facing resistance at the moment of adoption and implementation at one of more stratum.
Who would be the best audience for the CoCoFe to meet our objectives and how could we broaden and diversify this audience to increase its influence?
In addition to the players in the different stratum mentioned above, it is important to include government officials, specially technocrats and perhaps academicians and the scientific community, specifically those that are working or have worked and relate directly to the players in the different stratum and along the supply and demand sides of the fertilizer market.
What should the scope of the CoCoFe be? Which nutrient input sources should be included; only synthetic fertilizers, or also manure, biosolids, compost, etc.? Should other products such as bio-stimulants, nitrification inhibitors, urease inhibitors, etc., be included as well?
I believe the scope of the CoCoFe should be inorganic nutrient sources/fertilizer since given their physical and chemical characteristics, facilitate standardization and regulation, as compared to inorganic nutrient sources.
Considering the multi-sources of organic nutrients and the erratic nutrient content, depending on the organic sources, it makes it difficult to standardize organic materials as source of nutrients, and therefore regulate it. Organic material should be seen first and foremost, as soil amendment to improve the soil structure to increase microbial activity, water retention and cationic exchange, which facilitate the absorption of nutrients by the plant root; and secondary, perhaps as a not too important source of nutrients supply to the soil and the plants. Nutrient content of inorganic material can be considered a positive externality; therefore, supplementary to inorganic sources, not as the main source of nutrients. This topic of organic nutrient sources has been widely discussed by others in this forum during the past few days.
Perhaps organic nutrient sources will required other “CoCoOrgFe” in the future as the industry matures.
With respect to the use of bio-stimulants, nitrification inhibitors, urease inhibitors, etc., I believe they should be part of the discussion and the CoCoFe, since they can help improve nutrient use efficient and help achieve the stated environmental and perhaps the human hazards objectives.
Will the CoCoFe assist in promoting responsible and judicious use of fertilizers? Why or why not? What other suggestions do you have to help the CoCoFe meet our objectives?
Yes, CoCoFe has the potential to promote the responsible and judicious use of fertilizers, but only if the right audience, as discussed before, are brought into the discussion and plenty of time is spent in socializing the CoCoFe among the different stakeholders, which make take different rounds of discussions at different levels and years before the CoCofe comes to fruition and starts being implemented.
Additional comments:
The noted statement “The CoCoFe is not designed to provide specific recommendations on field applications of fertilizers, i.e. rates, placement, timing, etc…” is not congruent with the statement “The [CoCoFe] focus is more on discouraging fertilizer overuse” and with some of the stated objectives, especially 2, 3 and 4; the ones related to maximizing efficiency of nutrient fertilizer use and minimizing environmental contamination and the negative effeect on human health. All these are directly related to the 4R of nutrient stewardship, with direct implication to the application of fertilizer by farmers. Therefore it is suggested to revise the objectives or the noted statement should be eliminated or modified to make it clearer.
Although we can presume the audience of CoCoFe has a good technical knowledge and background on fertilizer, it is important to start a discussion of "terms and definitions” to be included in the CoCoFe. For example what is considered organic fertilizer and inorganic fertilizer? What are bio-stimulants? Etc.
It is important to beware that the regulatory burden from the adoption of CoCoFe, has the potential to impact on the cost of supplying and using fertilizer. This has higher implications for developing countries such as in SSA, considering that in these countries fertilizer production is almost non-existent and its use is low to negligible due to its high transaction costs along the international and domestic supply chains. Therefore, hindering or countering the efforts of international organizations and governments programs aimed at reducing the cost of fertilizer at retail.
Porfirio Fuentes
Dear Ronald and all,
Thank you for the quick feedback to my original comments. Please review the text below as a matter of response to your question: do you have any other suggestions? In reference to my comment of including the supply side of fertilizer industry in the CoCoFe.
Although I do appreciate the intent of the CoCoFe consultation facilitators to focus only on the use of fertilizer, I want to politely re-emphasize on the need to include the supply and demand side of the fertilizer industry, while supporting the point of view from other panelists who have also seen the need to make CoCoFe holistic by including the supply side of the industry.
To focus only on the use of fertilizer to minimize the negative externalities related to the environment and human health, is to ignore the negative externalities on the environment and human health of the supply side of the fertilizer industry and give a “clean bill of health” to the production and manufacturing processes while placing all potential regulatory burden that would emanate from CoCoFe, on the use of fertilizer. I do understand and can also appreciate the implications with the industry by addressing those issues in CoCoFe and I can also appreciate the ease of addressing such issues from the user perspective only; but the fact is, that there is a lot the industry can still do to help reduce and therefore minimize such externalities through improvements in the production and manufacturing processes. We know that many of the negative environmental and health hazards from the use of fertilizer have their roots in fertilizer production and manufacturing processes. Focusing on the use (demand) of fertilizer will help reduce such externalities, but having a holistic approach (which entails considering also the supply side of fertilizer), will definitely minimize them.
Therefore if we are to keep as part of the CoCoFe objectives, “to minimize environmental and health impacts from pollutants such as heavy metals in fertilizers”, we need to start at and focus also on the supply side of the industry for an effective minimization of environmental contamination and human health hazards by improving the production and manufacturing processes to reduce or eliminate contaminants (i.e., heavy metals) in fertilizers and perhaps by investing in developing more efficient fertilizer (a new generation of “smart” fertilizer products congruent with crop genetics technological advances); complemented with a more efficient use of fertilizer.
However, if the facilitators of this consultation insist on the CoCoFe focusing only on the use or demand side of fertilizer, I suggest to eliminate the rhetoric of “minimizing environmental contamination and health hazard from the use of fertilizer”, and keep this as an implicit, not explicit objective. Having said that, I suggest to consider the following objectives:
1. Increase food production to supply the increasing needs of more and safer food;
2. Maximize the efficient use of nutrients fertilizer to enhance sustainable agriculture production;
3. Minimize nutrients losses to the environment (GHG, runoff and leaching into surface water streams and underground waters) to reduce contamination and human health hazard.
Less and more clear objectives, will help simplify the elaboration the CoCoFe and perhaps facilitate its vulgarization.
I believe the rest of the points raised in my original comment, still applies.
Thanks.
Porfirio Fuentes
Please see my contribution to the CoCoFe consultation below, in the forms of response to the quesions posted on the original note above.
Thanks.
Given the global scope of the CoCoFe, do you think the objectives are appropriate? If not, how would you add to them or modify them?
In order to make a better judgment on whether the proposed objectives are appropriate, it is necessary to have a clarity on what the goal of the CoCoFe is. A goal can be defined as a broad, general, tangible, and descriptive statement.
With this definition in mind, I can presume that the CoCoFe goal, is “to promote the responsible and judicious use of fertilizers”. If this is the goal of CoCoFe, it seems to be narrowly focused on the use (demand side) of fertilizer, while the stated objectives, specially 3 and 4, related to environmental and health impact, have also mining, production and processing implications; also, 4 is directly related to fertilizer production and beneficiation. The CoCoFe “goal” as stated, with the “aim of assisting member countries design policies and regulatory frameworks for the sustainable use of fertilizers”, would place the regulatory burden on the use (demand side) of fertilizer while neglecting the negative externalities resulting from mining, production and other activities along the supply and value chain, reflected on environmental contamination and negative impact on human health.
Consequently, I suggest to make a small change to the CoCoFe goal to be stated as: “to promote the responsible and judicious supply and use of fertilizers” where supply embraces the activities of [domestic] production (including mining), processing, blending and all other value added activities along the supply chain; and, demand would include the needs of fertilizer or nutrient sources as feedstock at each stage of the value chain, perhaps emphasizing on the last stage of the supply-demand chains: the agricultural producer/farmer as final user of fertilizer.
Based on the proposed CoCoFe goal of “promoting the responsible and judicious supply and use of fertilizers”, the underlying objectives could be:
Alternatively, these objectives could be narrowed down to 3, as follows:
How should be the CoCoFe be structured to have the maximum positive impact?
CoCoFe should be structure in strata according to the different stages of production, supply and demand of fertilizer. Although this stratification can vary from country to country, it is possible to identify a generic supply-demand chain, from production to consumption, which would be applicable to almost any country. The stratification would resemble a cone, starting with general to specifics codes, where the codes of the top strata in the “cone” are applicable to the stratum below. Depending on how a country supply-demand chain is structured, the CoCoFe could start being applied at any strata below the top on the “cone”.
For example, the first stratum of CoCoFe could focus on the production of fertilizer, applicable to those countries with endowed resources to produce fertilizer (natural gas for producing nitrogen based fertilizer, phosphate rock and potash mines). Another stratum could be elaborated to be applicable to the transformation/processing fertilizer industry including blending. Successive strata can be importers, blenders, wholesalers, retailers and consumer or farmers.
On the same talking, for the current consultation to “better mold the future of fertilizer use globally”, must also include the different strata, perhaps in a simultaneous but separate consultation to make the CoCoFe more relevant and effective, otherwise it run the risk of facing resistance at the moment of adoption and implementation at one of more stratum.
Who would be the best audience for the CoCoFe to meet our objectives and how could we broaden and diversify this audience to increase its influence?
In addition to the players in the different stratum mentioned above, it is important to include government officials, specially technocrats and perhaps academicians and the scientific community, specifically those that are working or have worked and relate directly to the players in the different stratum and along the supply and demand sides of the fertilizer market.
What should the scope of the CoCoFe be? Which nutrient input sources should be included; only synthetic fertilizers, or also manure, biosolids, compost, etc.? Should other products such as bio-stimulants, nitrification inhibitors, urease inhibitors, etc., be included as well?
I believe the scope of the CoCoFe should be inorganic nutrient sources/fertilizer since given their physical and chemical characteristics, facilitate standardization and regulation, as compared to inorganic nutrient sources.
Considering the multi-sources of organic nutrients and the erratic nutrient content, depending on the organic sources, it makes it difficult to standardize organic materials as source of nutrients, and therefore regulate it. Organic material should be seen first and foremost, as soil amendment to improve the soil structure to increase microbial activity, water retention and cationic exchange, which facilitate the absorption of nutrients by the plant root; and secondary, perhaps as a not too important source of nutrients supply to the soil and the plants. Nutrient content of inorganic material can be considered a positive externality; therefore, supplementary to inorganic sources, not as the main source of nutrients. This topic of organic nutrient sources has been widely discussed by others in this forum during the past few days.
Perhaps organic nutrient sources will required other “CoCoOrgFe” in the future as the industry matures.
With respect to the use of bio-stimulants, nitrification inhibitors, urease inhibitors, etc., I believe they should be part of the discussion and the CoCoFe, since they can help improve nutrient use efficient and help achieve the stated environmental and perhaps the human hazards objectives.
Will the CoCoFe assist in promoting responsible and judicious use of fertilizers? Why or why not? What other suggestions do you have to help the CoCoFe meet our objectives?
Yes, CoCoFe has the potential to promote the responsible and judicious use of fertilizers, but only if the right audience, as discussed before, are brought into the discussion and plenty of time is spent in socializing the CoCoFe among the different stakeholders, which make take different rounds of discussions at different levels and years before the CoCofe comes to fruition and starts being implemented.
Additional comments: