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Farm breweries and the ALR

Posted by Rebecca Kneen on

There has been some press recently on the changes to the Act that governs the ALR, or Agricultural Land Reserve in BC. The ALR was instituted in the 1970s in an attempt to stem rising encroachment on farmland and to ensure that farm land remained within the economic grasp of new farmers. While there have been issues with some of the land included in the ALR, the Act itself was extremely progressive, and has overall really helped to keep farmland viable in BC. It has not solved all the issues, from government flooding of farmland in the Peace to removal of land from the ALR for development in the Lower Mainland, but it has helped.

Recent changes to the act governing the ALR have caused some issues with on-farm breweries - including us. We have been brewing on farmland for 17 years, with the initial approval of the ALC.

Our entire operation is designed to be integrated with the farm, so that we provide a net benefit to the farm and do not overstep our resource use. We make use of hops, fruit and herbs grown on the farm, and return brewery byproducts to the farm for livestock feed, compost feedstock, irrigation water and mulch. Our water use is the strictest in the industry, to ensure that we do not take more water which needs to be available to the farm. Our footprint for buildings and ancillary uses, 17 years in, is no larger than when we started, ensuring that we do not take up more growing land.

We feel strongly that since the new regulations were clearly not developed in consultation with either farmers or existing farm breweries, they should be amended to both support on-farm breweries and farmers.

Crannóg Ales opened in 2000, after several months of discussions with the ALC. At that time, there were no breweries on agricultural land (there were only about 8 microbreweries/pubs in the whole province anywhere!). The upshot of the discussions was that we were proposing an operational footprint that fell within the then current on-farm industry regulations, and we therefore did not actually need to apply to the ALC for any special dispensation. As long as our building was less than 900 sf, they had no issue with our operation. In fact, the members (including Russ Bullock) who came to discuss the brewery and farm with us were very pleased with our proposal to build something which genuinely tried to support the farm by using farm-grown ingredients, balancing farm water needs with brewery needs, and using all brewery by-products to enhance the farm. At the time, they suggested that we write an application simply so that they could base further decisions on it. We wish we had followed that advice, since here we are 17 years later being told that we don’t exist and are not allowed to do what we have been doing for so long.

At the moment, we are awaiting some sort of communication from the ALC, which has apparently forgotten that we exist. *** UPDATE March 11 *** The ALC has directed us to discuss changes to the legislation with the Minister, and says that they will discuss our compliance with us....

We support the Agricultural Land Reserve. There has to be some mechanism to ensure that we don’t pave/drown/build on all our agricultural land and continue to be able to feed ourselves, and to keep the price of farmland within reach for new farmers. We have spoken out in favour of the ALR at many public events throughout the years.

The issue which we see with the new regulations is that there is no understanding of how brewing actually works, with the removal of hops as an ingredient (!) and the inclusion of raw barley. There are three major agricultural ingredients in traditional brewing: malt, water, and hops. Hops are a critical ingredient requiring only drying and storage to be usable in brewing. Barley, on the other hand, cannot be used without undergoing extensive processing through malting to convert their starches to usable sugars. There is no custom maltster in western Canada, so the only option would be for on-farm breweries to take up more land by installing an in-house maltings and significant storage facilities. By contrast, Gambrinus Malting in Armstrong is currently working with local farmers, producing one batch from local organic barley this year (enough to supply Crannóg Ales with one month's production needs). Long-term contracts with Gambrinus Malting would be much more effective in encouraging local malting barley production. Malting barley is a barely viable crop in most of southern BC, as it has very specific seasonal requirements which are considerably different than those for growing feed barley. Hops, on the other hand, can be grown intensively in almost all of southern BC, making them a more viable crop.

In addition, there are no guidelines for percentage of land used for brewing processes and attendant storage, parking etc, nor for waste and by-product management. There are also no guidelines to ensure that the farm operation remains viable.

Our suggestions for alterations to the text of the Act are:

A brewery, distillery or meadery, and ancillary uses, are designated as farm uses for the purposes of the Act if
(a) at least 50% of any of the farm products used to make the beer, spirits or mead produced each year is grown on the farm on which that brewery, distillery or meadery is located, or
(b) the farm on which the brewery, distillery or meadery is located is more than 2 ha in area and at least 50% of any of the farm products used to make the beer, spirits or mead produced each year is grown
    (i) on the farm, or
    (ii) both on the farm and on another farm or processor using BC ingredients located in British Columbia that provides any farm product to the brewery, distillery or meadery under a contract having a term of at least 3 years. And,
(c) any permanent structures used to produce beer, spirits or mead must not exceed the lesser of 5% of total parcel size or 1000 square meters, including all ancillary structures or areas such as parking, water reclamation, tasting and public areas and storage. (Currently, Crannóg Ales uses 900 sf for the brewery, with shared storage and parking for the farm still keeping the total footprint below 300 square metres.)
**** please note that this footprint goal is smaller than that for which we have petitioned the government, as we feel that smaller footprints are more viable for the surrounding farm. ****

Further to section c) above:

Recognizing that these Regulations are meant to keep agricultural land for growing food, we recommend restricting the amount of the land used for breweries to be right-sized for both the parcel and surrounding community. This, quite frankly, will help prevent large, industrial breweries from effectively co-opting agricultural land for industrial process. We would also support policies which require that water use be restricted in a ratio of water used to beer produced, that all outgoing water be treated onsite to irrigation standards, and that the farm unit be evaluated separately for its independent viability.

We would also specify that on-farm breweries should be certified organic, to enhance the viability of the surrounding farms. Non-organic breweries use chemicals which contaminate the waste stream and would endanger the ecology of the farm, thereby making both current and future farming more difficult or impossible. Given that the idea of the ALR is to support long-term agricultural viability, this seems basic.

For more background:
Hops and hop farming are a perfectly valid and beneficial crop for BC farmers. We have, in fact, spent the last 10 years supporting, teaching and growing the number of hopyards in BC, ensuring that farmers have access to a different crop and income stream. There are a large number of farms now growing hops in BC, from 0.5 acre to 80 acres. Hops grow well in the range of soil and climatic conditions that exist in much of BC.  The hop market is growing with the increasing numbers of craft breweries in BC, enabling hops to be a viable part of many small farms, and to be the focus of larger operations. After all the work we've done to have hops included as a crop in the federal listings, it's bizarre to have them not included in BC as either an agricultural product or an ingredient in beer.

Craft breweries can, if located on agricultural land, add substantial agricultural value to that land. Rapidly escalating land costs in BC are making it increasingly difficult for new farms to get started or grow. Including value-added processing improves those economics, motivating agricultural land uses previously not possible. Additionally, the “waste” products from brewing including spent grain, hops and water are directly useful, once treated, as agricultural amendments in the form of compost, livestock feed and irrigation. Growing conditions of marginal farms can be improved substantially with the addition of on-farm brewing. Hops production also encourages livestock on farms, as intercropping with sheep and chickens is mutually beneficial.

We would like to see the ALC enter into serious discussions with the existing farm breweries to create regulations that support on-farm breweries while limiting size and land use, and ensuring that bogus operations are not permitted.

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