Submissions

As a result, while the CFA is generally supportive of the proposed policy on continuous oversight of pesticides, we wish to highlight the following concerns over potential risks in applying the policy: Unintended impact on PMRA’s resources and core mandate; Increased confusion concerning pest management products.

CFA provides feedback on the Critical Minerals List, recommending that the list include key minerals for agriculture such as phosphorus, nitrogen, boron, copper, iron and others.
It also includes a proposal to develop a Canadian Critical Farm Input Strategy based on the Critical Minerals Strategy.

CFA recommends that adequate resources are allocated by the federal government to develop accessible laboratory methodologies to effectively detect PFAS, and to develop risk assessments to understand the impacts of PFAS in biosolids applied as fertilizers. CFA also recommends the implementation of standards for source control of PFAS in the wastewater stream, in order to limit the presence of PFAS in the environment, including in biosolids.

Canada’s farmers and ranchers are concerned not with the European Commission’s proposed regulation itself, but with the lack of recognition of the unique accommodations and flexibility required for the humane transport of animals. These animal welfare practices are already well established here in Canada. For example, through the National Farm Animal Care Council, producers, along with animal welfare groups, enforcement agencies and government have collectively developed Codes of Practice for the care and handling of farm animals across Canada, including animal transportation.

The CFA and its members, particularly those in Eastern Canada, have expressed concerns with the significant crop damages caused by the growing Sandhill Crane population. In particular, the number of breeding pairs estimated by the ECCC-Canadian Wildlife Service’s Eastern Waterfowl Survey shows an average growth rate of 11% per year in Quebec since 1990 and 6% per year in Ontario since 2011. As a result, the CFA calls on the Canadian Wildlife Service to allow a managed hunt of Sandhill Cranes in Eastern Canada to help farmers mitigate crop damage caused by Sandhill Cranes.

Canadian agriculture and agri-food production is already playing an important role in supporting Canada’s biodiversity and contributing to the objectives of the Kunming-Montreal Global Biodiversity Framework (KMGBF). Through sustainable best management practices such as the maintenance of soil health, integrated pest management, agroforestry and the use of cover crops, Canadian producers are well positioned to continue the fight against climate change and support Canada’s biodiversity outcomes. As such, it is our view that Canada’s Biodiversity Strategy could benefit from a greater recognition and acknowledgment of the
positive role Canadian agriculture industry is already playing in supporting our biodiversity goals.

To help address many of the challenges faced by farmers, the Canadian Federation of Agriculture (CFA) has put forward 18 recommendations in several areas aimed at not only helping farmers manage the increasing cost of production and navigate challenging regulatory barriers, but also to help them mitigate the effects of climate change and support the next generation of farmers.

CFA provides comments on the Supply Chain Regulatory review concerning: Maximum Revenue Entitlement, Hours of Service Regulations, Extended Interswitching, Canadian Transportation Agency Own Motion Powers, Automatic Demurrage Penalties, Contracting Practices and Commodity-Specific Training for Canadian Border Service Agents.

The CFA opposes the uplisting of the Eastern Wolf from Special Concern to Threatened under SARA, without assurances that there be exemptions for certain protections on private lands, in order to ensure that farmers are able to adequately protect their livestock from the predator.

A letter urgently calling on Senators to vote against amendments made to Bill C-234, An Act to amend the Greenhouse Gas Pollution Pricing Act. These amendments excluded thousands of Canadian farmers from receiving critical financial relief, and raised the potential for a significant delay in the passage of Bill C-234.

A joint letter proposing the following amendments to Bill C-293, An Act respecting pandemic prevention and preparedness:

– Recommendation #1: That Section 4(2) (I) be removed to allow the Advisory Committee the flexibility to undertake its mandate and to focus its attention on pandemic prevention and preparedness. Specifically, our concerns relate to the use of the words “regulate” and “phase out.” It is recommended this wording be removed or changed to consistently use “assess” or “summarize.”

– Recommendation #2: That the Bill include language that encourages continued support and enforcement of existing biosecurity initiatives, including industry-led initiatives.

– Recommendation #3: That the reference to “high-risk species” in Section 4 (2) (I). iv. be clearly defined.

A joint letter of support for Bill C-244, An Act to amend the Copyright Act (diagnosis, maintenance, and repair). This bill has direct implications for the right for diagnosis, maintenance, and repair of farm machinery. The federal government has a clear role to establish a legislative structure that strikes a measured and appropriate balance with the intent to create a competitive market for equipment repair that will allow farmers the choice to safely conduct all repairs themselves, through a qualified third party, or through the OEM dealerships