Thank you very much, Mr. Chairman. I have to say right at the beginning that Cam and I feel a little inappropriately dressed, based on the comments earlier about the grain companies being Mother Theresa in drag, so next time we are invited before the committee we'll make sure we dress appropriately.
Thank you for inviting the Western Grain Elevator Association's views on the COMPAS review of the Canada Grain Act and the Canadian Grain Commission. The WGEA is an association of eight farmer-owned public and private grain businesses operating in Canada, and they collectively handle in excess of 90% of western Canada's bulk grain exports. WGEA members own grain-handling facilities throughout the country and at the ports of Prince Rupert, Vancouver, and Thunder Bay.
While we do not agree 100% with all aspects of COMPAS's report, we do believe that the report's recommendations would reform the system to bringing in the flexibility required for the changing markets. We applaud this committee for its work to initiate this legislative review that has generated the COMPAS report.
One of the very positive aspects in this report that we would like to highlight right at the beginning is the premise that all stakeholders, including the CGC, should be liable for their mistakes or misrepresentations. This is an important policy shift and one that we support.
On the issue of mandate, the report splits the mandate into two parts, which you know. Establishment of standards of quality for Canadian grain and regulation of grain handling in Canada for markets would be for the good of Canada and therefore the industry as a whole. The CGC's role in the interest of producers pertains to the right of delivery access, etc., and this clarification retains the CGC's role as a producer advocate. However, the change removes the ambiguity from the mandate.
We believe the recommendation brought forward by COMPAS would help resolve some of the internal conflicts while maintaining the commission's mandate to function in the best interest of producers. The WGEA believes that the report brings forward a balanced suggestion for change and should be supported by the standing committee and the Government of Canada, and it should be brought forward in amending legislation.
On the issue of governance, the change from a three-person board of appointed commissioners to a single CEO with vice-presidents and other senior executives is a positive change. This would take out much of the politicization that has arisen from the current structure. This model would give clear lines of accountability and responsibility, with ultimate authority lying with the minister, as it should.
The recommended changes to governance are strongly supported by the WGEA, and we ask the standing committee to support this recommendation and request that the changes be quickly drafted into legislation that can be brought before the House of Commons.
On the grain farmer ombudsman issue, the removal of the assistant commissioner position is a good change, for the reasons Conrad talked about earlier and for the reasons he has described in the report. The creation of the grain farmer ombudsman is a positive suggestion that would ensure the farmer's ability to have concerns addressed, and it's an enhancement from the current approach.
The creation of an ombudsman independent from the CGC might also help remove politics from policy decisions made by the CGC. The role of ombudsman is common in both federal and provincial jurisdictions, and these existing models could be used to help develop the structure.
On funding, we wish to preface our comments with a note of concern that the current funding of the CGC's operations may hamper Canada's ability to export. For example, there's a concern that CGC's policies governing the inspection of vessel loading on late shifts or on weekends may result in inspectors being unavailable. The COMPAS report acknowledges these concerns and specifically recommends that all overtime costs associated with inspection services be absorbed by the federal government. We suggest that this particular recommendation be implemented immediately, before the arrival of this year's peak shipping season.
COMPAS's recommendations regarding funding in general are necessary and are fully supported by the WGEA. We strongly believe that costs for activities undertaken by the CGC for the good of the country and/or the grain industry as a whole should be funded by the government and that cost-recovery components be limited to the marginal costs associated with individual services necessary for commercial transactions. Stable funding would help ensure long-run availability of a Canadian quality assurance system.
On the Canadian quality assurance system, we support the recommendation that the CGC collaborate with independent providers for customized inspection services.
One of the few positive items from the COMPAS discussion paper released in May was the recommendation that primary and export standards be harmonized. This recommendation is absent from the final document, and we respectfully request that consideration be given to preserving this change.
The report would make inward weighing and inspection optional, and the CGC's capacity to carry out inward weighing and inspection would be maintained at public cost in order to provide service to small handlers and farmers. We do not believe this recommendation would require legislative change, and we recommend the regulations be brought forward immediately. A move forward on this item would help relieve the budgetary pressure on the CGC in the short term.
COMPAS recommends the continuation of outward inspection and weighing. In our opinion, in the event that the CGC cannot provide these services, companies should be allowed the option of using third-party services. For example, we have a current situation in which the CGC may not be able to provide overtime services for outward inspection, yet they will not grant terminal exemptions.