Finance Committee on April 3rd, 2012

[The Chair, Conservative, James Rajotte]

I call this meeting to order.

Orders of the day—we are televised—are pursuant to the order of reference of Wednesday, December 7, 2011, a study of Bill C-311, An Act to amend the Importation of Intoxicating Liquors Act (interprovincial importation of wine for personal use).

This is our second session on this topic.

We have six witnesses before us here this afternoon: firstly, the Alliance of Canadian Wine Consumers; secondly, the British Columbia Wine Institute; next, we have Château des Charmes; we have the Grape Growers of Ontario; the Wine Council of Ontario; and our last presenter, Winelaw.ca.

I want to thank you all for being with us here this afternoon. We will allow you five minutes for an opening statement, and then we'll have questions from members.

We'll start with Ms. George, please.

[Shirley-Ann George, President, Alliance of Canadian Wine Consumers]

Thank you.

On behalf of Canadians, especially those who love wine, we are pleased that you have sought out the views of the Alliance of Canadian Wine Consumers. We represent a grassroots volunteer organization, more commonly known by our campaign name “Free My Grapes”.

We exist for a single purpose—that it should be legal for Canadians to directly buy from Canadian wineries and have the wine shipped across provincial borders for their personal consumption. We call this winery-to-consumer or WTC sales. Bill C-311, ideally with our proposed amendment, has our full support. I have five quick points to make, plus an important request on the amendment.

First, Canadians want interprovincial wine barriers removed. We believe there should be a single Canadian market and expect that everything should be available via the Internet. Bill C-311 will provide an opportunity for greater consumer choice, the ability to visit a winery and have the wine shipped home, to reorder this wine, to join wine clubs, and to go to a winery's website and order wines that you hear about through word of mouth or through local blogs.

Canadians are unwilling to accept this archaic prohibition-based law that has been mocked in major national and local newspapers, radio, and even the national evening newscast. Canadians in every province and territory support our cause. They have signed our petitions, sent letters to MPs, and joined us on Facebook and Twitter. There's even been one individual, Terry David Mulligan, who has been willing to go to jail in his protest of this law.

Second, this is affordable. Our WTC request has been carefully crafted to minimize the impact on provincial revenues. Our analysis, based on ShipCompliant data—which has been tracking the U.S. impact of direct-to-consumer sales, where it is legal in 38 of 50 states to ship across state lines—only 0.6% of a single one per cent of U.S.-produced wine is shipped across state lines. If we apply these numbers to Canada and assume no economic benefit, which is an ultra-conservative projection, 0.6% of 1% translates into 0.001 to 0.015 of the liquor board revenues, ranging from a potential loss to provincial and territorial treasuries of $44 in Nunavut to $619,000 in Ontario. These amounts can be easily recovered through cost savings. For example, WTC and a change of just 1¢ per bottle of wine sold would result in a revenue increase for each and every province.

On the plus-side, we believe that taxes, jobs, and other economic benefits will result in the provinces, more than covering their costs, and that wine-producing provinces will gain significantly from increased tourism, wine sales, and grape sales. The high cost of shipping wine means WTC is only attractive for wines not locally available and will be largely used for higher-end wines. As in the U.S., all this translates to 98% of wines still being purchased locally.

Third, the vast majority of Canadian wines simply are not available to Canadians. A quick tour down the aisle of your local liquor store clearly demonstrates that very few of the 450-plus wineries are actually represented, and the limited shelf space in existing outlets means they never will be.

Fourth, the greatest benefit is going to go to small and medium rural businesses. U.S. experience shows that every state that has allowed WTC has had their local wine sales increase, and most small wineries cannot or will not sell their wines through liquor boards. Also, wine and culinary tourism will increase.

Finally, this bill does not undermine the need or the ability of provinces to properly regulate the sale of wine. Provinces will still set the regulations, such as limiting the changes to winery-to-consumer sales. They will still ensure the protection of minors through such vehicles as licensing shipping companies and demanding proof of age at delivery.

Earlier I mentioned one area of concern, and I will quickly conclude with this. The current amendment is worded in such a way that liquor boards could flaunt the will of Parliament and not actually make a single change. Given that they have been unwilling to work with Canadian vintners and establish a winery-to-consumer framework and that the provinces have refused to respond positively to Minister Gerry Ritz's invitation to discuss the needed changes, we have no reason to believe, with the exception of British Columbia, that they won't just ignore Bill C-311. This will disappoint and anger Canadians, who widely believe that Bill C-311 will make a difference, otherwise why would we be spending our collective time and our collective money working on it?

Our request is that you add the word “reasonable” before “quantity”, and remove the word “and” afterwards.

There is legal precedent that demonstrates that such a change would not create the concerns raised by Mr. Albas, and the provinces would still have the ability to set quantity limits. This change would only encourage them to go beyond the pointless two bottles per year limit that some have today. Mr. Hicken is capable of addressing this further.

In summary, we're asking you to vote in favour of Bill C-311 with the amendment.

Thank you.

[The Chair, Conservative, James Rajotte]

Thank you for your presentation. We'll now hear from the B.C. Wine Institute, please.

[Miles Prodan, Executive Director, British Columbia Wine Institute]

Good afternoon and thank you for this opportunity to state the B.C. wine industry's case before this committee.

The B.C. Wine Institute is an organization of voluntary members that represents 95% of all wine production in the province and is wholly supported through member sales. The BCWI represents the interests of B.C. VQA—that is 100% B.C.-produced wine—in the marketing, communication, and advocacy of their products to all stakeholders.

Specifically, the B.C. wine industry has enjoyed tremendous growth provincially over the past five years, with over $4 million of average growth annually, and almost 9% over the last five years. With approximately 10,000 acres of grapes planted in B.C., the B.C. wine industry is small. Compared to 15,000 acres here in Ontario and 40,000 in Napa, for instance, we are a cottage industry. This bill goes a long way in helping us to grow our markets. Of the total of 210 grape wineries currently licensed in the province—an additional 24 growers have indicated they will start a winery in the future—approximately 80% produce less than 10,000 cases, and the majority of those are family-owned agribusinesses making fewer than 5,000 cases a year.

As of January of this year, of the total provincial B.C. VQA wine sales, 25% were sold through the B.C. LDB and 24% were sold directly from wineries, with the remainder sold through private liquor stores, restaurants, and the rest.

While it is difficult to estimate how many direct winery sales are done through wine clubs, in-province direct delivery, etc., the majority of B.C. wineries offer such services, and it is an effective and efficient marketing and distribution strategy, specifically for the small operators. It is reasonable to assume that a minority of wineries may currently be illegally shipping wine directly to customers, but the majority do not and are at a distinct disadvantage to those who may be.

B.C. wine tourism has been experiencing tremendous growth over the last number of years, specifically since the 2010 Olympics. We've seen a tremendous number of wineries making significant capital investment in accommodation, restaurants, and the rest to augment the wine tourism industry in B.C.

Provincially, wine tourism was estimated to be worth $75 million in B.C., according to a study done in 2003. While all agree that it's substantially more than that, the number is pegged at $75 million. It is a significant attribute of B.C. tourism.

As you are aware, the Importation of Intoxicating Liquors Act provides no legal exemption in federal law to transport wine across provincial borders, even for small quantities purchased for personal use. The IILA makes it illegal for Canadian wine consumers to take wine that is not purchased in or consigned to the province across a provincial border. It also prohibits a consumer from directly ordering out of province after returning from a B.C. wine tour.

Since June 2011, several liquor boards have allowed a quantity “on your own person” into the province. While this is an improvement, it is only of benefit to residents of border communities, and provides limited benefit to wine consumers or tourists who may have travelled, say, from Nova Scotia to British Columbia to visit wine country once every couple of years.

We see Bill C-311 as having a tremendous impact on the wine business of B.C. The number of wineries in B.C. has grown by 281% in the last ten years. Today, many of those are small family-based wineries focused on small-lot wine. The investment made in the B.C. wine industry has been in response to a growing interest in B.C. wine and tourism.

[The Chair, Conservative, James Rajotte]

You have one minute, please.

[Miles Prodan]

In conclusion, the BCWI strongly supports this bill and encourages the House of Commons standing committee to complete its review with the goal of achieving royal assent before the House rises in June.

We are encouraged by Premier Christy Clark's and opposition leader Adrian Dix's support of this bill and see that it will go a long way in helping to foster growth in the B.C. wine industry.

Thank you.

[The Chair, Conservative, James Rajotte]

Okay. Thank you very much for your presentation.

Now we move to the representative from Château des Charmes. Go ahead, please.

[Paul-André Bosc, President, Château des Charmes]

Thank you very much, Mr. Chair.

I will make my remarks in English, but if any members of the committee prefer to ask me questions in French afterwards, I can answer in French.

As I just said, I will deliver my main remarks in English.

My name is Paul Bosc. I'm the president of Château des Charmes wines in Niagara-on-the-Lake. This is a business that I have spent my entire adult life in. My father founded the business in 1978. My family came to Canada from France in the 1960s. My dad represents the fifth generation, and I represent the sixth generation of my family to grow grapes and make wine professionally. We've made wine on three continents.

I've had the opportunity over the course of my career to travel all over the wine world. I have built friendships and relationships with wineries all over the world.

I'm here to state that I firmly believe that the status quo, as we have it in this country, is anti-competitive and puts the Canadian wine industry at a distinct disadvantage to our foreign competitors who enjoy DTC privileges in their home markets. I can assure you that they are not holding hearings in France right now to debate whether a French winery in Bordeaux could ship wine to their customers in Paris. In fact, a winery in France can deal directly with consumers all over the EU market of 400 million potential consumers. As Shirley-Ann so rightly pointed out, right next door in the United States, 38 U.S. states permit DTC, which captures something like 82% or 85% of the U.S. population.

Why are we at a disadvantage? When you are cutting out the middleman, the wholesaler, or the retailer, and you act as the retailer yourself, this becomes a very lucrative channel. Wineries in other parts of the world that do participate in this trade are stronger in their home markets as a result. That, in turn, makes them powerful exporters. You can't become a powerful exporter unless you have a pretty strong position in your home market. I will use the French as an example again. They have 90% of their domestic market. It puts them in a good position to tackle an export market like Canada.

Much of the interest in DTC is tourism-driven. Canada is a very big country. It's very much about visitors to our winery who come to us from sometimes thousands of kilometres away, from Alberta, Saskatchewan, B.C., or Nova Scotia, and they would like to buy a couple of cases of wine. They would like some help to ship it back. It's just that simple. It happens to be my personal view that it is none of the business of the province they are from, or of the liquor board where they are from, what they are doing when they are visiting Niagara-on-the-Lake and wanting to buy a couple of cases of wine.

Now, I did mention that these are lucrative retail transactions. Wine is now made in six provinces in Canada. There are more than 400 wineries in Canada. Most of them are small family businesses.

[The Chair, Conservative, James Rajotte]

One minute.

[Paul-André Bosc]

If we were to sell a $75-dollar-per-bottle case of ice wine in retail, we collect on that case $152.59 in taxes—both provincial and federal taxes. These transactions generate lots of revenue for both the federal and the provincial government.

I can't comment on the entire IILA. It's more than 80 years of age. Maybe most of it has been quite successful. I don't know. It is certainly my view that after more than 80 years, this specific portion of the IILA is out of step with Canada in 2012. You are able to arrange, at your counter, to ship a few cases of wine all the way back to Asia, perfectly legally, for visitors from Hong Kong or Japan. And then beside them is a fellow Canadian who says, “That's great. Could you help me ship a couple of cases back to Calgary?” and I say, “Sir, I can't do that for you. You're a Canadian and it's illegal”.

[The Chair, Conservative, James Rajotte]

Thank you very much for your presentation.

We'll now hear from Ms. Zimmerman, please.

[Debbie Zimmerman, Chief Executive Officer, Grape Growers of Ontario]

Thank you very much.

The Grape Growers of Ontario support Bill C-311. We welcome the all-party support for expanding the cultivation and use of Canadian wine grapes. The legislation is well-intentioned, and if properly implemented, could be very helpful to our members. The excellent reputation of Canadian wines is spreading around the world. All Canadians should be able, legally, to enjoy our wonderful Ontario wines. It should not be easier to ship from a winery in Ontario to Memphis than to Montreal.

While we certainly do not want to stand in the way of this exciting initiative, we must ensure that the modifications proposed in Bill C-311 are the best or the safest way to achieve the goal. We believe that the initiative should apply—and we join with our partners in Nova Scotia—only to wines containing 100% Canadian grapes. However, we understand that the WTO rules require that equivalent competitive opportunity must be provided to all wines from all WTO members. Would Canadian wine blenders and bottlers of imported wine be far behind? Could Costco, offer their Juila Cellier—bottled in Quebec, foreign-origin—wines across the country? Our members are concerned that Bill C-311 could be much more beneficial to imported wine than to 100% Canadian. Could we lose more than we gain?

The Importation of Intoxicating Liquors Act is the basis for the liquor boards' right of first receipt. Amending this law could attract attention from NAFTA and the WTO. Should Canada be challenged about the way, or any way, or all provinces, or prominent provinces implement Bill C-311? Other, indeed, all liquor board practices based on the IILA could be challenged.

There were two challenges of liquor board practices under GATT in the late 1980s and the early 1990s, and Canada lost both. There was another EU challenge under the WTO a few years ago, and this was settled by more concessions than were made. These decisions were not only about markup. They also condemned Canadian practices on point-of-sale and direct delivery, which are at issue here.

Last week you asked whether U.S. practices had been challenged. In fact, Canada did challenge the U.S. on a wide range of their practices related to wine and beer. Canada won. That report was adopted by GATT in June 1992. Several practices linked to use of local grapes or local fruit wine were condemned. Earlier GATT and WTO challenges were settled on a negotiated and/or compromised basis. The WTO is more logistical than the GATT. Relitigating could result in great cost to Canadian wineries and grape growers.

I would say that hoping the changes pursuant to Bill C-311 will not be noticed or challenged is not sound business practice. Indeed, we know Mr. Dunning's testimony at the EU is closely being monitored.

We agree with Bill C-311. It is no doubt more politically attractive and would be popular—we realize that—but there are potential risks and downsides that need to be carefully examined to ensure that we're not opening a Pandora's box.

Thank you.

[The Chair, Conservative, James Rajotte]

Thank you, Ms. Zimmerman.

We'll hear from Ms. Dawson now, please.

[Hillary Dawson, President, Wine Council of Ontario]

Good afternoon.

I'm Hillary Dawson. I'm president of the Wine Council of Ontario. On behalf of our membership, I'm very honoured to be invited to come and participate in these committee hearings today.

The Wine Council of Ontario is the champion of Ontario's high-quality, authentically local vintners quality alliance wines, and of promoting wine country as a destination. As a non-profit trade association, the WCO represents 80-plus wineries from across the designated viticulture areas of the province. Our members are grape growers, manufacturers, and leaders in tourism in their communities. We're the future of Ontario's wine industry, which is a source of new investment, jobs, and award-winning wines. Additionally, the Wine Council of Ontario promotes the unique qualities of Ontario's locally grown wines through its consumer-facing brand Wine Country Ontario.

The Wine Council of Ontario is a strong supporter of Bill C-311 and has been encouraged by the support that this bill has received from all parties in the House. Clearly, there is consensus that modernizing our commercial relationships with our customers is an idea that's time has come.

One of the reasons that my member wineries have a strong interest in the passage of this bill relates to the challenges of our marketplace. VQA wineries in Ontario currently have the following sales outlets for their wines. First is sales through the LCBO. The LCBO is the sole avenue for mass distribution of wines in Ontario. It has two lines of business: LCBO wines, which it sells in larger volumes at lower price points, and Vintages, which is the key vehicle for sales of premium-priced wines. Though the LCBO is an excellent retail partner and a big supporter of VQA wine sales, Ontario's VQA wineries are mainly challenged by the lack of opportunities to connect with the consumer at the premium price level.

On average, Vintages has been releasing less than 200 VQA wines per year through this channel. Additionally, these releases can be as few as 20 cases, but generally are in the range of about 125 cases. As a result of these realities, VQA wineries are very focused on other avenues to sell premium-priced VQA wines.

Another important channel is sales to other provinces through liquor boards. The Wine Council of Ontario and its winery members have been actively engaging interested liquor boards across Canada to grow the presence of VQA wines on shelf. Channels, like the Manitoba Liquor Control Commission, have partnered with the industry to create promotions for VQA wine, which have led to sustained listings in that market.

It should be noted that these opportunities work best when there are market conditions for both winery and retailer that drive positive results. Not all provinces are interested in developing this market in this way, but the industry has been active in engaging as many as make sense, and will continue to do so in order to ensure a strong presence of 100% Canadian wines for Canadian consumers.

A third avenue for premium VQA wines is direct sales to the trade. When given the opportunity to sell directly to the customer, Ontario's VQA wineries have made a strong success in sales to trade in this province. From our perspective, the lesson around direct delivery is that our wineries are prepared to invest and hustle in driving sales in these channels, which are extremely competitive, and that with this personal service we can grow our business even in the face of imported wines and consignment pricing.

Fourth is our export of wines. This continues to be a significant opportunity for Canadian wines, particularly icewines. Working together under the auspices of a national export strategy, VQA wineries continue to grow the profile of icewines and premium table wines abroad.

Last but not least, our sales at the cellar door. For the vast majority of wineries in Ontario, transactions at the winery itself are the primary vehicle for sales. Currently in Ontario, there are approximately 130 wineries commercially active in producing and selling VQA wines. Cellar door sales are primarily driven through the significant tourism numbers that the wine country experience attracts into our market. It is at the cellar door that our customers make an important emotional connection to both the wine country experience and to the wines. This is what customers want to be able to subscribe to and bring back home. Whether this be an on-site transaction of any volume or a desire to reorder product, the inability to service this request directly for any Canadian out-of-province customers is embarrassing for the winery and exceptionally frustrating for the consumer.

These customers are very wine involved and have an expectation that they'll be able to continue this very personal relationship with their favourite winery at any time. Being able to service this customer directly will allow wineries to have a commercial relationship with their customer that parallels the one that they can have with virtually any other store or supplier currently.

I look forward to the discussions here today. Please know that the Wine Council of Ontario supports the proposed amendments as articulated by the Canadian Vintners Association. This will ensure that the bill's intended impacts are realized, and the opportunities it affords Canadian wine customers are clear.

Direct-to-consumer sales will give Ontario's VQA wineries an opportunity to continue relationships with their most interested and discerning customers. The passage of this bill will be an important and critical first step in being able to carry on these relationships in a modern commercial environment. This will complement the ongoing efforts of Ontario's wineries to grow their shelf presence and sales at both the LCBO and other Canadian liquor boards.

Thank you.

[The Chair, Conservative, James Rajotte]

Thank you very much, Ms. Dawson.

We'll now hear from Mr. Hicken, please.

[Mark Hicken, Vintage Law Group, Winelaw.ca]

Thank you for the invitation to speak on this important issue. I would like to briefly review four issues that are also covered in the brief I submitted.

The first is the legal effect of the current law. Contrary to what you may have heard, the current law entirely stops the direct shipment of wine from one province to another, and the personal transport of wine across a provincial border. In this regard, it's very useful to note that Canada's shipping prohibition is different from the U.S. equivalent law that says that interstate shipments are illegal, only if they violate the laws in the destination state. The absolute prohibition in Canada is problematic because on its face it even creates a problem if a province wants to allow the importation of wine from other provinces. I'll deal with that in more detail later, particularly in reference to the laws in Alberta.

It's important to note also that this matter is a matter of exclusively federal jurisdiction under the constitution. It deals with interprovincial trade, which is exclusively a federal jurisdiction under the constitution.

The second issue that I'm going to cover flows from the first one, and I'd like to illustrate why we need to reform at the federal level by using examples of what—

[The Chair, Conservative, James Rajotte]

You're getting some feedback on your mike, just back up a little.

[Mark Hicken]

Sorry.

The second issue that I'd like to deal with flows from the previous one. I'd like to illustrate why we need reform at the federal level by using examples of what the provincial liquor boards have done recently. Following a lot of media attention on this issue—mostly generated by Terry David Mulligan's cross-border run between B.C. and Alberta—a number of liquor boards have taken the position that it is in fact legal for individuals to personally transport wine between provinces, but that it is not legal for wineries to ship directly to consumers. For example, Alberta and Prince Edward Island have interpreted their own provincial laws to this effect, and the LCBO issued a policy statement in June 2011, also to this effect.

In my opinion, the LCBO policy statement is simply wrong in law. The Importation of Intoxicating Liquors Act, or the IILA, makes absolutely no distinction between the personal transport of alcohol and its shipment. Both of those actions are equally prohibited, and in my legal opinion, it is beyond the constitutional jurisdiction of a provincial liquor board to override a federal criminal prohibition by using a policy announcement.

It's arguable whether a province could change the effect of the IILA by passing its own provincial laws dealing with importation. However, I've included a quotation in my brief that shows you that as recently as 2009, the Alberta Gaming and Liquor Commission took the position that a provincial government could not do so, even though Alberta's own provincial laws clearly permit personal importation.

As a result federal action is needed, because we now have a situation with extremely problematic legal consequences. Firstly, provincial governments and liquor boards appear to be so embarrassed by the current law that they are making bizarre distinctions between the personal transport of wine and its shipment, when there is no basis in the relevant laws for those distinctions.

Secondly, provincial governments, such as Ontario, are trying to override the federal law using policy announcements, which in my opinion is untenable.

Thirdly, there are conflicts now between federal and provincial law, such as in Alberta, which produce unfair levels of uncertainty for both consumers and wineries.

The third issue that I was going to deal with is the likely effect on provincial liquor revenues if the amendments proposed by C-311 were adopted. I'm just going to say that I completely agree with the earlier comments of Shirley-Ann George on that issue.

My final point is that if amendments to the bill are possible, I think that the House should consider adding a definition of a minimum reasonable amount for personal consumption into the exemption. As it's currently worded, the bill leaves those definitions to the provinces. If that happens, that will likely result in a patchwork quilt system of regulation, like the United States currently has, or as Shirley-Ann said earlier, it may result in very little change at all to the current situation.

If we had a national minimum standard, then wineries could ship to that standard without any additional regulatory burdens. Provinces would be free to legislate their own choices above those minimum standards. Such a system, if it was put into place, would be better than the American system and would be much closer to what is in place in the rest of the world, such as in France, as Mr. Bosc mentioned earlier.

Those are my comments for now. I'd be happy to answer your questions.

Thanks.

[The Chair, Conservative, James Rajotte]

Thank you very much for your presentation.

We'll now go to members' questions.

Let's start with you, Mr. Mai. Go ahead, please.

[Hoang Mai, NDP, Brossard—La Prairie, QC]

Thank you, Mr. Chair.

My thanks to the witnesses for appearing today. Thank you for your submissions and your presentations.

We have to respect what exists today, namely a structure that allows the provinces to exercise some control. But then we have wine producers and consumers. We must find a balance.

Mr. Hicken and Mrs. George, you made the same argument as the Canadian Vintners Association. The amendments you are proposing would result in the federal government becoming more involved and giving more direction to the provinces. But the thinking is for the federal government to get out of this program and let the provinces run with it.

Mr. Hicken and Mrs. George, do you think that, by using the term “reasonable”, you are imposing conditions on the provinces that, according to them and to the Constitution, are actually theirs?

[Mark Hicken]

That's exclusively in the area of federal jurisdiction. The matter of interprovincial trade is exclusively an area of federal jurisdiction, so I don't see any interference with the provinces' jurisdiction on that issue. The federal government is free to legislate as it wants on that issue and in fact, the history of the Importation of Intoxicating Liquors Act is that the provinces asked the federal government to introduce the original IILA in 1928 because they did not have the power to regulate interprovincial trade. So if the federal government chooses to put a particular standard in there, it is certainly free to do so, in my legal opinion.

[The Chair, Conservative, James Rajotte]

I'm sorry, Mr. Hicken, we're getting feedback. We need some distance between you and your mike.

[Mark Hicken]

I'm sorry.

[Hoang Mai, NDP, Brossard—La Prairie, QC]

Maybe the question is now more in terms of balancing for the consumers. Can you tell us what the consumers want in terms of why this bill is good for them?

[Shirley-Ann George]

Thank you for the question.

This is something where consumers literally don't understand why the law exists. The comments I get.... Even in an interview that I did today, neither one of the folks who were on CTV News even knew that the law existed.

We have studies that show that over 75% of Canadians believe the law should change and almost an equal number admit that they have, in fact, transported wine or had wine delivered to them. So it's a law that isn't being adhered to today, and it is a law that Canadians do not support. The way that we have crafted our request, it is not a large financial imposition on the provinces at all. In fact, it is very small. So we have tried very hard to find the balance that you think is so necessary.

With our recommendation of adding the word “reasonable”, that does not force the provinces to set a specific amount, although that would be ideal. We believe, again, that we've tried to find the proper balance. “Reasonable” just encourages the provinces and the territories to review the amount that they set and to be able to justify that it is, in fact, reasonable. We believe this will be enough to encourage the provinces to set a limit that is more than something silly like two bottles of wine a year.