Ladies and Gentleman, hello from Edmonton. As mentioned, I am Dave Solverson, president of the Canadian Cattlemen's Association. With me is Ryder Lee. Many of you will know him; he's one of our people in Ottawa. I would like to say thanks to Ryder for digging deep into this agricultural growth act for me.
I am a cow-calf producer from Camrose, Alberta and also a backgrounder and a feeder. We have an operation that is a bit different. We take our calves right through to the finish. It has given me a good understanding of the challenges at each step of production. Along with my partners, I'm also involved in some grain farming production, and have been exposed to the ups and downs of that side of farming.
Bill C-18 covers a wide array of acts. Some of the changes are of obvious interest to livestock producers—the updates to the advance payments program, for instance—and some are not likely as obvious. I will comment on both.
The changes to the Plant Breeders' Rights Act are positive. Canadian cattle producers depend on innovation and improvements in feed grain and forages. We believe that the update to UPOV 91 will encourage investment in seed development in Canada. The protections this act confers are not just for companies, but also for institutions like universities and governments that develop new varieties of seeds. Two of our major competitors, the United States and Australia, have adopted UPOV 91, and we hope to keep pace with them.
There are overarching changes to several acts that merit comment. The first is the ability to incorporate by reference. The second is the allowance for the use of documents that are not Canadian. The third is the allowance for the minister to consider information that is available from a review or evaluation, conducted by the government of a foreign state.
We have often found the regulatory change process to be time-consuming, or to be duplicative of rigorous approval processes in other jurisdictions. We see these changes as positive for innovation and for regulatory processes in general. There are requirements set out for transparency and accessibility. The test will be when these things are done. Enabling them in this legislation is a good first step, and we will be involved when the authorities granted by these changes are first tested.
Skipping down to the Agriculture and Agri-Food Administrative Monetary Penalties Act, we do have some concern with how this is implemented, more so than with the authority granted in the proposed bill. The proposal is to set new penalty amounts for minor violations at $5,000, serious violations at $15,000, and very serious violations at $25,000. One reading could be that any violation could get at least a $5,000 fine. It's not clear that there will be a continuum within minor, serious, and very serious violations.
The current CFIA modernization consultation discusses compliance and risk-based enforcement that would lead us to believe that a minor offence of little risk to human or animal health would not yield a $5,000 penalty. This comes down to implementation. It is not something for which we have an amendment to suggest to the committee, but we did want to register this concern.
With respect to the cash advance, you'll be hearing from Alberta feeder associations and others about this program. CCA supports the legislative changes in C-18. Granting the authority to add breeding stock is a positive change, and changing some of the dates will make the legislation match up better with beef production than it did in the past.
We also support giving administrators more ability to handle the different kinds of business set-ups that exist in farming today.
We will continue to work with AAFC on this file. They've done a good job of consulting on the APP part of the C-18. As regulations are drafted to be put into force, and the authority is granted in the act, we will participate.
One of the things we will keep investigating is the ability to add the western livestock price insurance program to the list of programs that producers can use as security for the advance payments program. We'd like to see price insurance become a national program.
Thank you for inviting us to appear. I appreciate the opportunity, and regret that I'm not in Ottawa to talk with you all in person.
To close, the changes in this bill are positive, and should improve government operations in the policy area it covers. They follow other improvements we're seeing in market access, which we have loudly supported.
From here, we're going to Red Deer to join a labour forum. Labour shortages on farms, and especially at the processing plants, are hampering our ability to take full advantage of positive changes we've seen to date and expect in the near future.
We're going to need more Canadian workers to meet the new needs of markets such as China and the European Union. If we cannot get more willing and able workers on farms and in plants from Canada and abroad, we'll continue to lose out on opportunities the marketplace has presented and on improvements that legislation like Bill C-18 enables. This is already happening today.
Thank you again.