Thank you, Mr. Chairman.
Members of Parliament and observers, it is an honour to speak on behalf of the Prairie Oat Growers Association.
POGA represents about 90% of the oats grown in Canada. Our crop is worth approximately $1 billion annually and is a heart-healthy, nutritious crop. Canada is the world's largest exporter of oats, representing 70% of the global trade. We are very pleased to note there has been tremendous investment in domestic milling capacity, so we are working to add more value in Canada to those oats we eat here and abroad.
These past few months have driven home the importance of the agri-food sector, as farmers, ranchers, meat packers, millers and retailers have been on the front line of response. Agriculture truly is an essential service. In this light it is more important than ever that we improve the business risk management programs. AgriStability, AgriInvest and the cash advance program should help address risks due to issues such as weather, market access issues and other factors beyond our control. AgriStability can be difficult for producers to collect even when income falls below a sustainable level, leaving unmanageable risk for producers. In particular, the challenges with AgriStability fall in five areas: it's not transparent, it's not predictable, it's burdensome administratively, it's inadequately funded and it's hard to access. Farmers report AgriInvest is easier to use, with strong predictability, bankability, transparency and a low administration burden.
Oat growers support the call by many groups, including Grain Growers of Canada and the Canadian Federation of Agriculture, for the immediate injection of a minimum of 5% of producers' 2018 allowable net sales into AgriInvest accounts, which is one of eight actions outlined in our submission. These eight actions are needed to address immediate crises, not only caused by COVID, but also prior disruptions to trade in multiple countries, including China and Italy.
In the medium term, one, we suggest this committee consider recommending the following: increase the AgriStability benefit trigger level to 85% for the 2019-20 program year, and for the remainder of the Canadian Agriculture Partnership; remove the reference margin limit; increase the maximum payment to $5 million; allow for retroactive enrolment for the 2019-20 program year; and put systems in place to process claims more quickly, including requests for interim payments. These changes will give farms and financial institutions confidence to keep operating and to keep credit available.
Longer term, to address AgriStability's current challenges, we would propose the following.
First, reinstate the AgriStability reference margin to 85% instead of 70%. There have been significant cost increases since 2013, when the margin was reduced.
Second, align the reference margin with producers' tax filing methods and use the net profit as determined on taxes with the same allowable expenses to be included. POGA realizes this may require a change to the reference margin, but then it should be predictable and verifiable. Farmers would not apply if it were in a profit position. This would also lower the administration burden on both the government and producers, reducing costs.
Third, when a producer increases their production insurance, for example, to 80%, that insurance payout should not be allowed to be included in the reference margin for AgriStability because the producer has paid a fee to buy insurance, and they should not be penalized for that.
To be clear, POGA would prefer that AgriStability be increased to 85% and improved. Should 85% not be reached, POGA does not believe that AgriStability will meet farmers' needs, and for the subsequent cap period, BRM programs should be altered to consider the following options.
The first is to eliminate AgriStability and increase the AgriInvest percentage to a 5% match.
The second is to eliminate AgriStability and put 100% of those dollars to increased crop insurance coverage to greater than the current 80% maximum level, and/or reduce administration costs.
The third is to increase the interest-free portion of the advance payments program from $100,000 to $250,000. It should be open to all commodities. Several commodities, including oats, have been negatively impacted and need security loan programs. The move to $250,000 would be 25% of the $1-million maximum allowable, which is consistent with the ratio of interest-free to maximum allowable in prior years, which was previously $100,000 of $400,000.
These options would require additional considerations. POGA supports the increased interest-free amount for the advance payments program that was provided in 2019, but believes it should have been applied to all crops.
On applications for the APP, it is recommended that a lower administrative burden be implemented for loans of $250,000 or less. Currently every credit supplier and banking institution must sign a priority agreement, which is very time-consuming. For loans of $250,000 or less, it is suggested that priority agreements are needed from three creditors or 60% of the farm operations creditors, whichever is less.
Cut AgriStability, but increase crop insurance coverage percentage and allowable expenses to cover labour, depreciation, carbon tax, equipment, etc. Also, most farmers do not have off-farm jobs. Farming is their employment, and therefore it should be expected that they take a salary at a set amount per acre.
Cut AgriStability, but increase the amount paid for AgriInvest to 5% with no maximum. While this would, on paper, increase total dollars from the federal government, it would eliminate all risk for the government and put the responsibility on producers to save that money to use in tough years. This would also significantly reduce the administrative costs of the BRM programs, as AgriStability is very labour intensive.
In conclusion, functioning business risk management is critical for farmers and the country. BRM programs must be monitored for effectiveness, and there needs to be methods for refinement at more regular intervals.
Farmers and agricultural businesses are the backbone of Canada’s rural economy. Rural communities frequently see less investment in infrastructure, services and job creation than other areas. With this in mind, it is important to consider that business risk management is one of the primary ways the Government of Canada not only supports its farmers but its rural communities as well.
Thank you, Mr. Chair.