Mr. Chair, ladies and gentlemen of the committee, thank you for giving us the opportunity to contribute to your consideration of Bill C‑39.
I am speaking today on behalf of the Union des producteurs agricoles, or UPA, which represents 42,000 agricultural producers in Quebec, as well as private forestry producers.
To be clear, we are in favour of better project coordination, more efficient processes and more effective supply chains. However, a fundamental question remains: What problems is this bill seeking to address? Is it the lack of resources within government departments or the protection rules themselves? If those rules are considered to be obstacles, then we are targeting the wrong issue. Why should safeguards be permanently weakened in the name of efficiency? What urgency justifies circumventing them?
For the UPA, efficiency must never take precedence over rigour, democracy, the environment or Canada's ability to produce its own food. Yet Bill C‑39 raises serious concerns in this regard. By making permanent powers that were presented as exceptional when the Building Canada Act was passed under closure, the government is crossing a major line. An exceptional measure responds to an exceptional situation. When it becomes permanent, it is no longer an exception—it is a new way of governing. We therefore call for the five-year limit under the current system to be maintained.
The proposed one-year time frame for obtaining federal approval must under no circumstances take precedence over seasonal studies, independent expert assessments and the evaluation of cumulative effects. The federal agencies responsible for assessment cannot simply validate developers' studies; they must be able to rely on independent experts. As for producers and other affected parties, such as the UPA, they must have access to documents in timely fashion and be given sufficient time to be genuinely consulted. Finally, federal coordination must be carried out in accordance with provincial regimes, particularly those that protect agricultural land and regulate private forests in Quebec.
By trying to move too quickly, we risk turning administrative streamlining into a democratic setback and making mistakes that undermine our rights and sacrifice our resources. What room is left for debate when speed becomes the priority?
We are also concerned about the provisions relating to regions of national interest. This mechanism creates a presumption in favour of certain projects and undermines case-by-case assessment. Yet the impacts on agricultural land and activities, water and ecosystems cannot be adequately assessed at the level of an entire region. They must be examined on a project-by-project basis, taking into account cumulative effects as well. That is why we are calling for the removal of this provision.
We support the development of strategic infrastructure and the improvement of trade corridors. Our sector depends on inputs arriving on time and on reliable transport networks to get products to market. However, there is a fundamental contradiction in seeking to strengthen Canada's economic security while undermining its capacity to produce its own food. Farmland is not vacant land awaiting development. Together with water, it constitutes a strategic asset—the foundation of our food security and the health of our ecosystems. Protecting these resources does not mean holding back development; it means preserving the conditions that make it possible.
With regard to part 3 of the bill, a last-resort mechanism may serve the national interest when a labour dispute has serious and disproportionate effects on the country as a whole. The 2019 propane crisis demonstrated the impact that a disruption to supply can have on agricultural businesses. However, this power must remain exceptional. It must be governed by rigorous criteria, be used only after all other remedies have been exhausted, and fully respect workers' rights. It must never become a shortcut for resolving labour disputes.
To conclude, our message is simple: yes to better coordination, yes to more efficient supply chains, but no to perpetuating the exceptional powers arising from the adoption of Bill C‑5, no to regions of national interest and no to measures that undermine rigorous project assessment and the protection of agricultural land and private forests.
If the government is seeking a permanent national interest, we already have one: food security in Canada. A country that can build faster but is unable to protect its ability to feed itself becomes poorer, not stronger.
Thank you.