Thank you Mr. Chair, and hello committee members.
As noted, I'm Larry Thomas, manager of environment and sustainability for the Canadian Cattle Association. I'm pleased to share some of our views on the act and to provide some clarity about our members and their typical day-to-day activities as they relate to fish habitat protection. Hopefully, this will help the committee understand how the impacts of this legislation on our members can pose significant burdens as you proceed through this Fisheries Act review process.
The CCA is the representative organization of Canada's 60,000 beef farmers and ranchers. The vast majority, 98%, of beef cattle farms and ranches are small to medium-sized. They're family-owned and -operated, with an average herd size of 69 head of cattle.
These are typically tight-margined operations that are located in every Canadian province. Some of these families have been on these working landscapes for well over a century. Our producer members take care of over 35 million acres of what's left of an endangered natural native grass ecosystem, and overall, Canadian beef producers manage more than 44 million acres of tame and native grasslands.
Access to surface fresh water and water bodies is critical for the viability and sustainability of many of Canada's beef farms and ranches. Water is conveyed and used on these operations for irrigation, livestock consumption and general farm and ranch operations. In many situations, man-made agricultural structures are important features in enabling the conveyance and use of surface water supplies. These can include irrigation or livestock watering infrastructure, man-made reservoirs and ditches and more.
That often means that our members create and manage on their lands what could ultimately become fish habitat. In many cases, farms and ranches conduct their routine low-impact works and activities in and around surface waters, and thus fish habitat.
CCA has been active in the consultations with DFO since prior to the act's coming into force in 2019. Our ongoing concerns centre in part around DFO's lack of pace on the implementation regarding regulations, standards and new, expanded and improved codes of practice.
We were encouraged when DFO revised the code of practice for beaver dam removal to allow for dismantling by heavy equipment rather than by hand, as noted in the initial draft release of that code. We were unsuccessful in getting DFO to include in the code the ability to remove a beaver lodge. It should be clear that if you remove the beavers and then remove the dam but leave the beaver lodge intact, that lodge will be populated soon enough, and you're back to the costly and time-consuming business of beaver dam removal fairly soon.
We also see the need to add other codes of practice, including culvert removal and installation, not just maintenance and shoreline stabilization. With effective communications with stakeholders, we believe that even more codes can be created that would improve efficiencies across the board. The CCA continues to encourage DFO to work with provinces and territories in coordination to ensure that regulations avoid duplication and contradictory requirements and to reduce the need for landowners to hire costly consultants to help wade through a matrix of regulations.
With regard to the time and costs to acquire an authorization, we suggested that DFO create an online mechanism that is easy to understand and use. DFO recently launched a zone on their “projects near water” website, with sections on requesting a review and applying for authorization. We feel this tool remains far too complex for many of our members to utilize, and it would likely require hiring a specialist to help, again adding cost to what is usually a low-impact activity.
The CCA has conceptualized a potential process to streamline the authorization permitting process for low-impact routine works and activities as they relate to beef farms and ranches, based somewhat on what is known as the safe harbours approach.
We would be happy to provide details on that proposal if the committee desires. We have provided a summary of our recommendations in the notes the committee has, but for the sake of time, I'll stop here.
The CCA appreciates this opportunity to relay our concerns and recommendations to the committee.
Thank you very much.