Thank you, Mr. Chair. It's a pleasure to be here. Thanks for having us on the committee today.
My name is Geoff Wood. I'm the senior vice-president of policy for the Canadian Trucking Alliance. The Canadian Trucking Alliance is a federation of the provincial trucking associations. It represents over 5,000 member companies across Canada. These employ approximately 250,000 individuals dedicated to supporting the national and international trucking supply chains.
We are pleased to speak with you today and highlight three key items from our pre-budget submission—which we submitted earlier this year—that we felt would be of interest to the committee. These include addressing the misclassification of workers in our industry, dealing with the underground economy and tax evasion, expanding and making permanent the accelerated investment incentive, and addressing the carbon tax. We believe that, with this pre-budget, we have an opportunity to take a serious look at the state of the trucking business in this country and take steps to better support Canadian businesses, the economy and the trucking industry.
The CTA is looking to bring back a tax system and business environment that incentivize growth and ensure fair competition. I'd like to stress the fair competition piece, which I'll get to in a bit. We have a crisis on our hands. It's only getting worse, and we need the government's help.
Now I'll cover my three points.
The first addresses the misclassification of workers and deals with the underground economy and tax evasion. For over five years—I said, “over five years”, but it's actually much longer than that—the Canadian Trucking Alliance has been calling on the federal government to combat gross non-compliance in the trucking sector, which includes widespread labour abuse and tax evasion. However, for many years, those pleas went unanswered and the abuse grew exponentially.
In 2022, in reaction to industry calls, ESDC launched an enforcement pilot project to investigate industry concerns in Ontario. As expected, this enforcement pilot found gross non-compliance, with more than 60% of employers in contravention of labour laws. For context, we believe 60% represents a substantial non-compliance figure, one that ESDC has never seen before.
Likewise, the Canada Revenue Agency, at the request of industry, launched a similar study in 2023 on the use of personal services businesses, which are the instrument of choice for those participating in the underground economy and the trucking industry. Like ESDC, the CRA found widespread non-compliance and tax evasion. Additionally, the study confirmed that trucking is now the number one user of the PSB model in the entire economy.
In both cases, the federal government studied the misclassification issue known as “Driver Inc.” and has independently confirmed what industry has been saying for a long time: Canada's trucking industry will soon be lost to the underground economy if we do not act now. Non-compliance in these areas allows operators to significantly reduce their operating costs and distort market economics. It also strips workers of many of their rights, including overtime pay, vacation pay, paid sick days and workers' compensation. This is just plain wrong and we need to fix it.
To put the tax evasion in perspective, it's estimated to be in the billions of dollars annually. It's estimated that a third of the trucking industry is in the grips of the underground economy. This issue needs urgent attention, including the lifting of the T4A enforcement moratorium, a real enforcement strategy from the Canada Revenue Agency to deal with non-compliant PSBs, and more enforcement of Canada Labour Code's part III as it relates to trucking. From our perspective, we just want the law enforced. We aren't asking for anything other than the law to be enforced. Please help us.
With respect to the accelerated investment incentive, this was introduced in 2018. We like it. We'd like to see it expanded and made permanent. Specifically, we'd like to see first-year deductions of up to 80% on all trucks and trailers being acquired. This spurs investment in clean and newer technologies. On a more aggressive front, we'd like to see aggressive rates of up to 100% for natural gas, hydrogen fuel cells and electric trucks, in order to promote these alternative-fuel technologies. As I mentioned earlier, we would like to see this made permanent. It's a good thing. The trucking industry supports it. It incentivizes business.
With respect to the carbon tax, no wholly viable alternative currently exists, so the current tax serves no policy purpose in the trucking sector. Diesel is the primary fuel used to power long-haul trucks. The federal carbon tax is intended to encourage truck operators to switch to less carbon-intensive alternatives, which don't currently exist in the long-haul sector and won't for the foreseeable future. Therefore, this tax misses its intended purpose in trucking, as it cannot alter fuel-purchasing decisions and doesn't provide any benefit to the environment.
In 2024, carbon taxes will add just under $2 billion to annual trucking costs in Canada. By 2030, the carbon tax will add more than $4 billion. Over the 12-year phase-in, the total cost to the industry will be $26 billion. Due to razor-thin margins in the trucking industry, these added costs cannot be absorbed and must be passed on to consumers.
As virtually every good purchased by Canadian families and businesses involves truck transportation, this means those families and those businesses are paying increasingly higher prices for those goods.
Mr. Chair, thank you for your time.
This concludes my remarks, and I'm happy to take any questions.