Submissions

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 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.

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.

We recommend that the government support Canadian National Railway (CN)’s proposal to seek a regulatory exemption to Transport Canada’s Grade Crossings Regulations for specific crossings where cost-effective alternative measures could be implemented that would provide the same level of safety.

Should Transport Canada not grant these exemptions, we ask that the railways bear the cost of upgrades and improvements and that the financial burden does not fall to farm families.

– We recommend that the government support Canadian National Railway (CN)’s proposal to seek a regulatory exemption to Transport Canada’s Grade Crossings Regulations for specific crossings where cost-effective alternative measures could be implemented that would provide the same level of safety.
– Should Transport Canada not grant these exemptions, we ask that the railways bear the cost of upgrades and improvements and that the financial burden does not fall to farm families.
– We also recommend that the government work with other railways, like Canadian Pacific Kansas City, to further identify specific crossings where cost-effective alternative measures could be implemented.

CFA recommends the following revisions to the proposed guidance:

– Modify the guidance document to ensure the common name and brand name of plantbased alternatives to egg products prohibit the use of the term “egg.”2
– Adopt an accurate and transparent approach to common names by implementing a structure that requires plant-based alternatives to egg products to use descriptive naming.
– Implement firm rules to prevent the use of terms typically reserved for and associated with eggs such as omelette, frittata, quiche, scramble and meringue on the label, packaging and
advertising of plant-based alternatives to egg products.
– Ensure any plant-based alternatives to egg products that includes “protein” in their common name and/or brand name, achieves a protein quality rating using PER (Protein Efficiency
Ratio) of at least 20 to remain compliant with Food and Drug Regulation (FDR) B.01.305.

A joint letter signed by 21 organizations was sent to the Minister of Finance with the following recommendations:

– We urge the government to simplify the Canadian Entrepreneur’s Incentive and broaden its eligibility to all sectors to support equity, simplicity, and transparency.

– We urge you to scrap the increase in the inclusion rate to 66.7%, which will affect many business owners who are part of Canada’s middle or aspiring middle class.

– The increase in the Lifetime Capital Gains Exemption and its indexation into the future are welcomed announcements and should be retained and protected.

The CFA recommends the workshops to draw upon farm-level experiences, in addition to identifying strategies and best practices that increase the farmers’ resilience, reduce GHG emissions, and sequester carbon at scale.

CFA would also like to be engaged with ECCC when building Canada’s Nationally Determined Contributions (NDCs) and Canada’s 2035 Emissions Reduction Plan.

The programs, and policies to support long-term climate objectives cannot ignore short-term implications for the farmers’ ability to face the immediate threats of climate change while maintaining the viability of their operations and delivering on food security objectives.