Submissions

CFA does not support the continued use of a single positive sample as the threshold for an index field. Spore detection should be confirmed in two separate samples within the same field before the field is classified as an index field.

The CFA supports the addition of a viability assessment for spores detected in potato fields when no visible tuber symptoms are observed.

The CFA supports the new “Field of concern” classification, as it would address some of the risk to the industry, associated with false positive or false negative test results. However, we suggest the following wording: “A field where spores in only one sample have been detected and confirmed via morphology and molecular analysis will be designated a field of concern.”

The CFA wishes to express some concerns regarding the proposed greenwashing provisions, especially as these provisions could have unintended consequences due to insufficient consultation and undefined terminology, which could lead to a potential increase in frivolous lawsuits, that could have a negative impact on the agricultural sector and be increase the workload of the Bureau’s employees.

We strongly urge you to take immediate steps to ensure the labour disruption between the GWU and the VTEA does not further damage our international reputation and negatively impact Canadians farms and farm families across Canada.

Biosecurity on farms is of great importance to Canadian producers, as well as to Canadians as a whole, as breaches in biosecurity can result in the loss of animals which would impact food security, jeopardize the national food supply, affect international trade relations and the economy, and impact the mental health and wellbeing of producers, their families, and employees. Canadian farmers ask for your support of Bill C-275, An Act to amend the Health of Animals Act (biosecurity on farms) to help ensure the continued biosecurity, safety, and wellbeing of Canadian farms and farm products.

For decades, farmers have focused on reinvesting in their operations to maintain competitiveness, enhance productivity, and continually improve practices to do more with less. For most Canadian farmers, these investments are made with an understanding that the assets they invest in will position them to maintain both the financial health of the business and ensure they can maintain quality of life into retirement. These sudden, fundamental reforms to Canada’s capital gains taxation, undermine plans that are often decades in the making and challenge the financial stability of capital-intensive multi-generational family farm operations.

While national standards are essential, it is crucial that these standards are adaptable to the diverse conditions across Canada’s provinces and territories. Housing challenges vary significantly depending on regional contexts—for instance, seasonal housing shortages in British Columbia, unique conditions in Quebec’s rural areas, and the distinct needs of operations in Nova Scotia. These regional differences must be taken into account to ensure the standards are both effective and feasible.

Transport Canada’s Grade Crossings Regulations do not explicitly state who is responsible for bearing the financial burden associated with the newly mandated safety upgrades. In the past, these upgrades and ongoing maintenance have always been performed by the railways, at the railways expense. Our concern is that in cases where pre-existing agreements are not already in place, the railways are now taking unilateral action to shift the cost burden for maintenance and upgrades of private crossings onto farmers, where they traditionally have done so, under threat of removing an existing and active private railway crossing altogether. Furthermore, we are hearing from our members of cases where farmers have received 30-day notices to close their crossings or that their crossing was removed by a railway without any notice.

The industry supports the safe handling of anhydrous ammonia through the Code of Practice. But, at present, there is no evidence suggesting that change to the current regulations is warranted, or that forcing farmers to have and maintain an expensive ERAP will reduce the number of incidents involving anhydrous ammonia.

Given theses concerns, we request that Transport Canada rescind their proposed amendments to section 1.24 of Transportation of Dangerous Goods Regulations.

The CFA uses the data from the FMS to inform its reporting and messaging on the sustainability, productivity, and innovation within the Canadian agricultural sector. The data allows us to quantify the impact of best practices with validated information to inform policy positions, and advocate for continued development of a resilient agriculture sector in Canada.

The pending disruption of Canada’s two national rail carriers, CN and CPKC, poses a significant risk to our industries and the broader Canadian economy and even our natural environment. Not only does a prolonged work stoppage threaten our international reputation, but places upward pressure on inflation and the cost of consumer goods thereby threatening our national food security. For this reason, we are urging the Minister to consider using section 107 of the Canada Labour Code to direct the CIRB to help parties reach an agreement under binding arbitration.

The simultaneous labour dispute between CN and CPKC and the Teamsters Canada Rail Conference (TCRC) union will have a devastating impact on the transportation of goods into this fall harvest. In addition to the shipment of agricultural products to market, farmers in many parts of Canada require a steady and stable supply of propane for grain drying, greenhouse production and heating and cooling of livestock barns. In fact, I understand that CN has already stopped shipments of “hazardous items” including fertilizers, ahead of a potential work stoppage, and at a time when shipments were being ramped up for next spring. The inability to
access these products at critical stages of production could result in food loss due to spoilage, acute animal welfare concerns due to a backlog of livestock slaughterhouse capacity, and the inability to maintain business continuity due to a lack of essential inputs.

The potential simultaneous disruption of Canada’s two national rail carriers, CN and CPKC, poses a significant risk to our industries and the broader Canadian economy and even our natural environment. Not only does a prolonged work stoppage threaten our international reputation, but places upward pressure on inflation and the cost of consumer goods thereby threatening our national food security.