Submissions

To strengthen Canadian competitiveness, we strongly urge the incoming government to take the following action:

– Unlock private sector investments through competitive tax policies that level the playing field with other jurisdictions, particularly the U.S., such as accelerated depreciation or investment tax credits on infrastructure and supply chain investments.
– Reform regulatory processes for the approval of infrastructure and major resource projects so that decisions are made quickly, with timing predictability clear from the outset, while allowing for adequate public consultation.
– Modernize Canada’s labour laws to mitigate economic harm and improve supply chain reliability by establishing a clear and transparent process to resolve
disputes rapidly in the transportation sector.

The CFA supports the goal of providing Canadians with measures that prevent misleading labelling practices, including “greenwashing”, that empower Canadians to make informed decisions.

However, the CFA continues to express concerns regarding the greenwashing provisions, the proposed guidelines, and the extension of the private right to action to environmental claims. These concerns are exacerbated by the current political and economic uncertainty currently facing Canada.

As detailed in CFA’s previous submission, the newly added provisions are vague and undefined, especially terms such as “internationally recognized methodologies”. Furthermore, the CFA is concerned with the potential increase in frivolous lawsuits due to the expansion of the private right to action that would push businesses to remain silent and thus contribute to “greenhushing” instead of effectively combatting “greenwashing”.

CFA submitted a letter to the Ministers of Finance and National Revenue to express concerns with the decision to administer the proposed capital gains inclusion rate legislation without parliamentary approval.

CFA recommended that the CRA does not move forward with these changes unless they receive parliamentary approval, as these changes would have negative impacts on farm succession.

The submission expressed concerns with the potential implications of any proposed measures to impose a tax on residentially zoned vacant land.

Specifically, CFA’s main concern with the proposed new tax measure is the potential for agricultural lands to be misclassified, leading to unintended taxation and additional financial strain on farmers, as many agricultural lands may appear vacant due to crop rotations or the need to leave the field fallow.

As a result, the CFA recommended that the Government of Canada consider an explicit exemption for land that is in use for agricultural purposes, regardless of the zoning classification.

CFA submitted its comments on the proposed new National Potato Wart Response Plan.

At a high-level, CFA recommended the following:
– CFIA requires adequate funding and human resources for implementation of the plan.
– CFA supports increased funding and research into resistant potato varieties.
– Update the CFIA compensation regulations, as they have not been revised since 2003. It should address the loss of future potato revenue and the devaluation of land.

Considering the increasing incidence of extreme weather and other disaster or emergency events which are costing the agriculture sector and the Canadian economy billions every year, the CFA understands the need for, and is generally supportive of, Canada’s Emergency Management Framework for Agriculture in Canada.

However, we offer the following specific comments on the Framework, for consideration as the Department of Agriculture and Agri Food Canada (AAFC) gathers insights on ways to improve the Framework:

– Clarify roles and responsibilities
– Increase capacity building
– Enhance visibility, understanding and communication of the framework
– Incorporation of new emerging threats
– Incorporation of Lessons Learned from COVID-19
– More structured post-emergency analysis
– Better alignment of Business Risk Management (BRM) programs as part of response and recovery activities
– Ensure that commodity / sector-specific emergency management traceability programs are recognized

The committee’s amendments to Bill C-275 diverge significantly from the original intent of the legislation, which sought to provide targeted intervention against the biosecurity impact and risk that individuals who come onto farms without authorization introduce to farming operations. These amendments are not supported by the members of the Canadian Federation of Agriculture, Canadian Cattle Association, National Cattle Feeders Association, Canadian Pork Council, and Canadian Meat Council.

Rather than addressing these important biosecurity concerns and taking a step forward in strengthening the overall safety of our food system, the proposed amendments risk punishing Canadian farmers, their workers, and invited guests in the event of a biosecurity breach and place additional burdens and mental stress on the very people who feed our communities. More specifically, Bill C-275 as amended fails to recognize that farms have little to no ability to intervene or enforce their protocols when someone unlawfully enters a farming premise.

CFA calls on the federal government to keep the limit permanent at $350,000 to reflect ongoing pressures due to inflation and high input costs. In doing so, the government would be following the recommendations set out by the House of Commons Standing Committee on Agriculture and Agri-food in its report entitled “Grocery Affordability: Examining Rising Food Costs in Canada.”

To ensure that family farms can access this credit, we are recommending two solutions:

Firstly, we recommend that the tax credit be extended to all family farms, including those structured as sole proprietorships and partnerships.

Secondly, we recommend that these businesses that hold qualified farm or fishing property assets be eligible to include current directors and officers as specified on the company’s corporate records towards their count of “employees” towards the tax credit.

On October 31st, CFA provided its submission to the 21st Century Workforce Consultation, with the following high-level points:

– Chronic labour shortages are impeding growth in the agriculture sector.
– There is a need to take a multi-pronged approach to building a modern 21st century labour market.
– The importance of building capacity and leveraging existing assets.
– The ongoing need to for temporary migrant labour as well as increased pathways to permanency.

On October 31, the Canadian business community sent a letter to Minister MacKinnon expressing deep concern regarding the indefinite strike by CUPE 375 at the Port of Montreal.

CFA provided a submission to the CUSMA consultation with the recommendations below:

– Maintain the existing rules-based framework that is part of CUSMA.
– Address non-tariff trade barriers and bolster regulatory harmonization through the Regulatory Cooperation Council.
– Continue to ensure that sanitary and phytosanitary measures are science based. The measures must be applied in a clear, predictable, non-discriminatory way.
– Address the extra-territorial impact of local trade barriers that affect the movement of goods between countries (e.g., California’s Proposition 12).
– Continue to allow parties to set phytosanitary measures that follow WTO rights and obligations while protecting food safety and animal health.
– Chapter 31 of CUSMA—dispute settlement—must remain in place.
– Create an effective mechanism that ensures unwarranted trade barriers are addressed quickly.
– Continue to improve the import and export processes between countries that emphasize automation.
– Review articles to ensure they are evidence based and limit unneeded redundancies.
– Increase competitive market opportunities for agricultural goods while respecting the needs of supply management.
– Ensure proper labelling standards, including the labeling of country of origin, to ensure that consumers are provided with sound, factual information about the product they are purchasing.
– Ensure that CBSA and CFIA are adequately resourced and trained to enforce CUSMA’s terms.
– Maintaining or expanding Canada’s market access to the US market which must be “wholly obtained” from sugar beets.