Thank you very much, Mr. Chairman and committee members, for giving me the opportunity to offer the seed industry's perspective on barriers to domestic trade.
As Mr. Shipley said, my name is Patty Townsend, and I'm the CEO of the Canadian Seed Trade Association, or CSTA.
The CSTA is the national voice for the seed industry in Canada. Our association represents 130 companies involved in all aspects of the seed industry. They're engaged in all production systems: conventional, organic, and systems that use modern biotechnology. We work with over 50 different crops, and our members range from small family-owned companies to large multinational companies. Our sector in 2012 contributed $5.61 billion directly to the Canadian economy.
The CSTA's mission is to foster seed industry innovation and trade. We work to create a regulatory and trade environment that encourages investment and provides opportunities for our members to conduct their businesses domestically and internationally. We focus a lot on international barriers to the trade of seed, but it's also important to look in our own backyard. We appreciate the fact that you've undertaken this study.
Generally speaking, unlike the wine industry, seed trades pretty freely across provincial boundaries. However, the barriers that we do have or that we face are potentially very negative for our industry. We have a robust and internationally respected science-based federal regulatory system in Canada, overseen by the Canadian Food Inspection Agency, Agriculture and Agri-Food Canada, Environment Canada, and Health Canada. These regulatory bodies have the jurisdiction, the expertise, and the resources to create regulations, provide oversight, and enforce the regulations when they're required. However, there are some provinces that have implemented or are planning to implement additional provincial regulations that are not in step with other provinces. They run contrary to federal regulations and they're not based on science. Most of this presentation is going to focus on science.
One major issue for the seed industry for over a decade now has been dealing with the Province of Alberta's strict regulations on fusarium graminearum, which is a fungal pathogen, mostly of cereal crops. As you heard earlier from Cereals Canada, in 2002 the Alberta government, believing that Alberta was free of fusarium, launched by regulation an enforceable management plan in an effort to prevent its establishment. Now, more than 10 years later, fusarium is present and well established in Alberta, despite the existence of the management plan. It's being found increasingly in wheat, durum, and barley in widespread areas of the province.
The current fusarium management plan requires that in order for farmers to have access to seed, the seed must be tested and found to be “non-detect”. Given the presence of fusarium in other provinces and in the United States, it is difficult to source higher generation pedigreed seed from which seed growers in Alberta and elsewhere can produce seed for Alberta farmers. In addition, seed produced in Alberta that presents even with extremely low levels of fusarium needs to be moved out of the province and sold as grain instead of seed, at much lower prices.
Recent scientific reviews concluded that tolerance levels for seed with up to 5% fusarium could protect those areas in Alberta that are relatively free of fusarium. Tolerances of up to 10% would not affect the infection levels in those areas where fusarium is already established, yet despite the science, the non-detect requirement remains.
A rough analysis by CSTA members indicates that retail prices for wheat seed in Alberta range from 12% to 19% higher than in Saskatchewan and Manitoba. There are cases where the inability to source seed of new varieties has meant that Alberta farmers don't have access to those new varieties, and they're at a comparative disadvantage to farmers in Saskatchewan and Manitoba.
In keeping with the need to base decisions on science, I need to state again that in order to be successful and to remain competitive as an industry, we rely on government and regulators at every level to make sound decisions based on reputable science. Sound scientific principles are measurable, reproducible, and predictable, and they apply equally to all stakeholders. Regulatory assessments and approval processes based on science ensure that all products are assessed consistently, giving confidence to consumers and to the developers of innovation.
Health Canada, specifically the Pest Management Regulatory Agency, or PMRA, is charged with evaluating, approving, and then cyclically re-evaluating crop protection products to ensure that they meet health, safety, and environmental standards using strict science. The PMRA has the mandate, the expertise, and the resources to carry out this work.
However, there is a growing trend among some provinces that feel that they require additional regulations that don't conform to science-based approaches and rather loosely apply their own interpretation of the precautionary principle. Practically ignoring the federal regulatory processes, provinces can create and are creating their own regulations, resulting in a regulatory patchwork that puts seed companies and growers at a competitive disadvantage compared to not only other provinces but also the United States.
CSTA seed company members invested $110 million in plant breeding and variety development in Canada in 2012. In order to continue to expand that investment, all plant breeders, public and private, need clear, transparent and uniform regulatory systems.
With few exceptions, seed may not be sold in Canada unless it's of a registered variety. Variety registration is overseen by the Canadian Food Inspection Agency, but recommendations for registration are made by committees that are provincially or regionally based. That means that varieties can be registered for sale in some regions and not in others. This situation combined with the Canadian Grain Commission's listing of varieties eligible for classes creates a tremendous amount of confusion and makes for a less transparent system for variety developers and for farmers.
For example, of the 144 varieties listed in the Grain Commission's Canada Eastern Red Spring wheat class, 45 are not registered in Quebec, 23 are not registered in Ontario, and 17 are not registered in either province. Many others are not registered in Atlantic provinces.
If we look at the Canadian Food Inspection Agency's list of registered varieties of spring wheat, things get even more complicated, because 46 spring wheat varieties are registered only in western Canada, four are registered only in Quebec, and two are registered only in Ontario. Bringing Atlantic Canada into the mix once again just increases the confusion.
It's not legal to sell seed of unregistered varieties. CSTA is hopeful that the modernization of Canada's variety registration system will address this situation and reduce the confusion and the cloudiness in the system.
I'm probably pretty close to my time, so I'll stop here. I look forward to questions.