Thank you, Mr. Chair.
I want to take this opportunity to thank the committee for hearing us here today. My name is David Marit. I'm president of the Saskatchewan Association of Rural Municipalities. With me here today is my good friend and our vice-president Jim Hallick. As a bit of background about the organization, we are an independent voluntary association representing all of Saskatchewan's 296 rural municipalities.
The railway system in Saskatchewan is vital to our province, perhaps more than other provinces. Railways provide the primary method by which farmers and producers can move products and commodities to market for export.
Competition is absolutely essential to the success of our agrifood industry. Competitiveness is threatened by CN's delisting of 52 producer car loading sites across western Canada, 24 of which are in Saskatchewan. Delisting means, of course, that producers can no longer order cars to be sent to that site to load grain. Western Canadian farmers have long been able to order their own grain cars and load them themselves. The right was legislated in 1902. The economic savings to producers who choose to load those cars has been estimated at more than $1,200 per car.
In recent years there has been a renewed interest in using producer cars because of transport cost savings. The most recent statistics from Quorum Corporation's grain-handling report indicate that over 12,000 producer cars were loaded in western Canada in 2006-07. This is a record number of producer car loadings. The statistics for Saskatchewan are equally impressive: 1,572 producer cars were loaded in our province in 1999, and in 2006-07 that number climbed to 8,971.
Clearly the system is widely used, and every indication points toward expanded use in the future. But in addition to this, we must emphasize that it costs nothing to maintain a siding on a producer car loading site. These sites allow producers to load commodities for transport, and CN's proposal to delist these sites means that our province's already few transport options will be reduced even further.
Once a railway siding is rendered inactive through delisting, it becomes easier for the rail companies to justify the discontinuance and ultimate abandonment of the siding itself, which would further reduce available transportation options. This would result in an awkward and centralized transportation system that does not accurately reflect producers' needs and requirements.
SARM recently presented a resolution at the Federation of Canadian Municipalities' rural forum that would seek proper and appropriate protection for rail sidings by amending the definition of “railway” in the Canada Transportation Act. That resolution was unanimously passed. The resolution is timely, because delisting a loading site means that a siding is potentially inactive. An inactive siding is one that could be discontinued, and once a siding is gone, it is gone for good.
We are aware of statistics that show that a very small percentage of producer car loading sites have been underutilized in the past. However, it is plainly evident that overall usage has been steadily and consistently increasing, so now is not the time to be delisting sites.
We are frustrated at the lack of transparency in the delisting process. We do not know what criteria CN used to delist the sites; we do not know who was using the delisted sites or for what purpose; and up until late yesterday afternoon, we did not know if any objections had been registered with the Canadian Transportation Agency during CN's 60-day delisting notification period.
SARM learned late yesterday, after much investigation, that 14 individuals and organizations submitted complaints and objections to the proposed delisting, but they did so only after the 60-day notification period had expired and the matter became public knowledge.
These 14 letters to the CTA, eight of which were from Saskatchewan, were all dated on or after September 5, which was well after the official delisting announcement had been made. This circumstance tends to suggest that these people and organizations were simply not aware of CN's intentions until after the public comment period had drawn to a close.
By advertising the notification to delist the sites in obscure and little-read regional publications, CN followed the letter of the law but not the spirit of the law. SARM is therefore asking for an immediate halt to the delisting of these 52 sites. We also request a moratorium on future delisting of all producer car loading sites until such time as the Canada Transportation Act can be changed to allow for a more transparent delisting process.
By transparency, we mean the following. Rural municipalities in the general area of the proposed delisted site must be notified and allowed to respond. The notification to delist a site must be published in either one or both of our two provincial major daily newspapers or the Western Producer, and we want CN to publicly display the criteria it uses in determining which sidings to delist. We want publicly and easily accessible information that indicates if there were any objections to the proposed delisting during the 60-day period.
This request for a legislative change to the Canada Transportation Act is important to us for one primary reason: our provincial grain economy depends almost entirely upon having an adequate and responsive rail network, and we need to have simple and ready access to any information that threatens this economic well-being.
According to the Quorum Corporation's annual report, the railways have plans to discontinue an estimated 700 miles of track in western Canada over the next three years. Five hundred and seventeen miles of that track was discontinued in western Canada in 2007-08 and 400 miles of that track was in Saskatchewan. The continued abandonment of rail lines, combined with the threat of increased siding discontinuance as a logical result of the closure of producer car loading sites, means that our province is faced with significant challenges, not only to our options for transport but also to our road infrastructure.
Every rail line that is closed, every siding that is ripped up, and every producer car loading site that is shut down necessarily result in an increase in road traffic and a consequent increase in the need for road repairs. Saskatchewan is in the enviable position of having one of the most vibrant and healthy short-line railway industries in the country. A ninth line was established this summer and a tenth line is in the works. This industry relieves an already overburdened road network, offers producers reliable and inexpensive transport, maintains the basic integrity of our transportation system, and fosters competition, which we understand as a necessary good.
We believe more can be done to ensure that the short-line industry is accommodated and encouraged. Rail line transportation is a vital issue in Saskatchewan and is one that we do not take lightly. Although the delisting of producer car loading sites may have the superficial appearance of being a small issue, we assure you that it is not. Once a loading site is delisted, the rail siding on which the loading occurred is inactive, and an inactive siding is an easy target for discontinuance. As we mentioned earlier, once a siding is discontinued or abandoned, it cannot be replaced. It is gone.
CN announced its intentions to delist 24 sites in Saskatchewan. From the perspective of Saskatchewan, the implications are frightening.
Thank you, ladies and gentlemen, for hearing our submission.