The process is flawed. The CFIA model is not one that we want to emulate. The CFIA model, which they used quite often throughout their different departments, which is online consultation, is really impossible for farmers to access.
For one thing, farmers don't go to the CFIA website, nor would they go to the COMPAS website. Very rarely do they go to the Agriculture and Agri-Food website.
Understanding the complexity of the issues...and then having the opportunity, as a public consultation online, to give feedback, is really not public consultation at all. Even in the example of the National Forum on Seed, the national forum on fertilizer.... You have these national forums that are public consultation by invitation only. They are also extremely flawed.
For farmers, who are not publicly funded, not privately funded, but self-funded, to participate at these national forums is literally impossible. It's very difficult. And the online consultation is ridiculous. It's not something you want to emulate.
For example, we have the CFIA regulating certain GMOs. Recently they regulated high-lysine corn, and there was an opportunity to speak to the issue of high-lysine corn. Now, they regulated it based on substantial equivalents, but countries around the world have not regulated high-lysine corn because the science is flawed.
But they did not do it on a science base. The CFIA says they are science-based, but they actually regulate based on substantial equivalents. It's one example of its being highly flawed. Unless you understand the science and you understand the process, it's very complex.
The consultations done online or through public or national forums are flawed, and it's impossible for the public to participate.