Thank you.
At the start, I would like to say that, like many of you, I was shocked at the passing of Gord Brown this morning. Gord was a great advocate for agriculture. Our thoughts are with him and his family at this time.
As many of you know, the Canadian Federation of Agriculture is Canada's largest general farm organization. We represent producers through general farm organizations and commodity organizations across all of the provinces. Many of these farmers are impacted by the implementation of the Fisheries Act, particularly with respect to farm drainage.
At the outset, I should say that farmers are stewards of the land and aspire to leave the healthiest environments possible, from one generation of farms to the next. I could even give examples of what has been done on our own farm.
Many find intrinsic value in supporting biodiversity and water quality on the land. At the same time, farmers recognize that they are contributing to the public good and services with little or no compensation provided.
We seek a Fisheries Act that supports, not hinders, farmers' ability to remain good stewards of the land, while remaining profitable and competitive. CFA was concerned that changes to the current Fisheries Act would bring back the problems farmers experienced pre-2012. Indeed, I met with you on November 21, 2016, to provide advice from CFA's perspective on this committee's review of possible changes. We applaud this committee's report. Extensive consultations with Department of Fisheries and Oceans occurred in 2016 and 2017 and I believe that, as a committee, you and the government have listened to our concerns and our advice. The proposed amendments to the Fisheries Act go a long way to addressing Canadian Federation of Agriculture's concerns; however, the devil is always in the details.
Pre-2012, the experience of farmers was not positive, as it was characterized by lengthy bureaucratic applications for permitting and authorizations; a focus on enforcement and compliance measures, which were taken by officials, often with a lack of consistency; and a lack of guidance or outreach on the purpose of the measures being taken, or information on how to navigate through the process. Also pre-2012, the Fisheries Act was cumbersome and created major delays for farmers seeking to do minor work, like clearing drainage systems on their land.
As a former municipal politician, I should mention that some of these same challenges were faced by municipalities for minor works, as outlined by Ray Orb.
With the current Fisheries Act, many farmers were relieved when changes were made a few years ago that drastically improved the timeliness and cost of conducting regular maintenance and improvement of activities to their farm. It lifted the threat of their being deemed out of compliance.
Nevertheless, with this act, there were concerns expressed around a cumbersome DFO permit application process and the lack of information and guidance from the department on how to navigate through the system.
Under the proposed new act, there are many aspects that are welcome, such as the possibility of establishing a minister's advisory panel. That was lacking in previous versions of the act, as farmers and others had no formal means to provide ongoing advice.
There are commitments to streamlining the regulatory burden of the act, which we also welcome. However, further details and regulations need to be developed, before we know whether this will be approachable for farmers and rural municipalities to navigate.
As we understand it from discussions with the Department of Fisheries and Oceans, implicit in these commitments is a commitment by government to consult with those affected.
The proposed act also promises greater clarity for all, which we greatly welcome. The proposed act introduces the development of codes of practice, which would provide guidance for agricultural works and others, with the promise that there would not be a need to apply for and receive a permit for the proposed activity, as long as the farmer follows the codes.
We need to engage the industry in discussion about how these codes of practice are developed.
While further transparency for Canadians is always welcome, again, we need to work with the Department of Fisheries and Oceans on any requirements for farmers to put their information about a project on a public registry, as well as what monitoring and compliance obligations this comes with. For a single owner-operator and small operations, we're concerned that, at the outset, this may place undue regulatory administrative burdens upon farmers, for whom this will be out of their field of expertise.
Farmers may also be concerned about their confidentiality, as, unlike most businesses, farmers live and work at the same address. This public registry may be better suited to projects that require permits, not those that would be developed under the codes of practice.
The CFA welcomes this bill, which includes financial investments to enable the Department of Fisheries and Oceans to manage the transition to a new act and to update regulations and implement them on the ground with the required support and expertise.
The House standing committee in its study of this subject recommended that farmers be given sufficient safeguards, and we maintain that generally accepted agricultural practices and those that actively work to minimize any impact to fish habitat by operations and maintenance should not be unduly burdened by the regulatory process.
We also look forward to working with the Department of Fisheries and Oceans to advance stewardship opportunities over enforcement ones. As I mentioned in a previous appearance, stewardship versus regulation will get farmers to respond and reach the end goal of protecting habitat.
We look forward to working with the Department of Fisheries and Oceans to ensure that the regulations are developed in a manner that respects the agricultural practices that are needed to efficiently and reliably produce food for Canadians and for export.
Thank you.