Government Operations Committee on April 10th, 2024

[The Chair, Conservative, Kelly McCauley]

I call this meeting to order.

Good afternoon, everyone. Welcome to meeting number 116 of the House of Commons Standing Committee on Government Operations and Estimates, also known as the mighty OGGO.

Pursuant to Standing Order 108.3(c) and the motion adopted by the committee on Wednesday, February 14, 2024, the committee is meeting to consider matters related to federal regulatory modernization initiatives.

I'll give a reminder to not adjust your earpieces near the microphone, as it causes feedback for our very valued interpreters.

We have four opening statements, and we'll start with Mr. Greer. We'll go from my left to your right.

Before we do, I want to make a short comment.

It's my 25th wedding anniversary today, so I want to give a shout-out to my wife for putting up with me for 25 years. I will note that I granted her gift request, which was to be away from her in Ottawa today. Happy anniversary to my lovely wife Sasha, and maybe we won't get to 26.

We'll start with Mr. Greer with a five-minute opening statement. Please keep it to no longer than five minutes, because I don't want to have to cut you off. Thanks very much.

Please go ahead, Mr. Greer.

[Ryan Greer, Vice President, Public Affairs and National Policy, Canadian Manufacturers and Exporters]

Thank you for having me here today on behalf of Canadian Manufacturers and Exporters.

Manufacturing generates 10% of Canada's GDP and produces nearly two-thirds of Canada's value-added exports, employing 1.8 million people in high-paying jobs across the country.

It doesn't take more than a cursory look at Canada's key economic indicators to see that we are in a growth crisis. Just two weeks ago, the senior deputy governor of the Bank of Canada called Canada's lagging productivity “an emergency”.

CME is pleased to participate in your study and share our thoughts on part of what is contributing to our economic malaise—Canada's regulatory competitiveness. Canada is an increasingly challenging jurisdiction in which to start a manufacturing business, invest in it and grow it. Canadian manufacturers are caught up in an increasingly complex web of rules and requirements that prevent businesses and their employees from reaching their full potential.

When we survey our members, a large majority of whom are small and medium-sized manufacturers, the regulatory burden consistently polls as one of the biggest barriers to growing their business.

Over the last two decades, the federal government has undertaken a range of regulatory red tape reduction initiatives and reforms. They have all been useful to varying degrees, but fall well short of what is required to reduce the ongoing accumulation of red tape that is removing the dynamism from our economy.

This assessment applies to the Treasury Board's current federal regulatory modernization agenda. While there are some worthwhile tools in it, it is too modest in its scope and its ambition.

With that in mind, I'd like to share some of CME's recommendations on how the government should make Canada more competitive.

First, we recommend that the government legislate economic growth and competitiveness mandates for all regulators, alongside their current mandates. Presently many regulators do not sufficiently consider the economic consequences of their actions, because they are not required to. We can achieve both protection and prosperity, but only if the government sets an expectation that economic growth is an outcome that all regulators should be working towards.

In the 2018 fall economic statement, the government announced that it was considering implementing a change to add “regulatory efficiency and economic growth” to regulator mandates. However, after two rounds of consultations in 2019, this idea was quietly abandoned.

This change could be modelled after the U.K. growth duty, implemented there in 2017, which provides detailed guidance for U.K. regulators on how they can better support sustainable economic growth through the decisions they make and the ways in which they regulate.

We believe this is the most important policy change that this committee could recommend and that the government could undertake.

There are other steps the government should take to reduce the cumulative burden facing manufacturers and all businesses. We believe the government should expand the scope and ambition of the one-for-one rule. As committee members here will know, this rule requires that for every new regulation that increases the administrative burden on business, the cost of this burden must be offset through other regulatory changes.

Despite this rule being in place for over a decade, the number of overall administrative requirements on business have continued to increase, from 129,000 when the federal government first started tracking this figure in 2014 to 149,000 as of mid-2022. That's a net increase of nearly 20,000 new administrative requirements over eight years.

We also think there is an important leadership role for the federal government in working with the provinces to undertake a serious effort to reduce interprovincial trade barriers and promote regulatory harmonization among provinces through mutual recognition. Most of Canada's interprovincial trade barriers are the costs of complying with rules, regulations, standards and certifications that vary from one province to another. Mutual recognition would provide that any one province should allow any product, service, credential or other certification to be considered automatically compliant if it is already so in another jurisdiction.

The 2017 Canadian Free Trade Agreement did create a body, the regulatory reconciliation and co-operation table, to resolve interprovincial regulatory differences; however, it has proven to be not fit for purpose. While it has done some valuable work, it simply does far too little far too slowly.

Last, and while perhaps not as transformative, we do believe that there are small but meaningful steps the government can take to strengthen some of the regulatory modernization tools already at their disposal.

For instance, the External Advisory Committee on Regulatory Competitiveness, first established in 2018, provides advice to the President of the Treasury Board on how to improve Canada's regulatory competitiveness. It has made a series of excellent recommendations to the government, including in its most recent letter, stating that “What we heard from all that there is an urgent need to address the challenges that face the regulatory system.”

We recommend that Treasury Board adopt a “comply or explain” principle toward the committee's advice, which means that the government is obliged to either pursue the proposed initiatives from the committee or explain why they will not be pursued. This “comply or explain” principle would add a level of accountability to the work and to other government consultation panels.

To wrap up, the ability to navigate complex regulatory processes should not be a primary driver of business success in Canada. However, it has become so. In the face of the current growth crisis, it is essential that governments invest more of their time and energy to help make Canada a lower-friction economy. Doing so will help create a more efficient and competitive industrial economy while increasing the wealth and well-being of Canadians.

Thank you.

[The Chair, Conservative, Kelly McCauley]

Thank you, Mr. Greer.

Ms. Pohlmann, welcome back. Please go ahead for five minutes.

[Corinne Pohlmann, Executive Vice-President, Advocacy, Canadian Federation of Independent Business]

Thank you. Good afternoon, and thank you for the opportunity to be here.

As you may know, the CFIB is a not-for-profit organization representing the interests of over 97,000 small and medium-sized businesses across Canada. Our members come from all sectors of the economy and all regions of Canada.

It is important to distinguish between regulations that are justified and excessive regulations, which we know of as red tape. Many regulations are integral and needed in our system, such as those that protect the health and safety of Canadians. On the other hand, red tape is excessive government regulations that are unfair, overly costly, poorly designed or contradictory. Red tape can also include unnecessary delays and poor government customer service. Red tape undermines productivity, lowers wages and harms the entrepreneurial spirit.

CFIB first estimated the cost of regulation to Canadian businesses in 2005. Our most recent measure, from 2020, found that the total cost of regulation on businesses from all levels of government was $38.8 billion. Of this, businesses identified 28%, or $10.8 billion, as excessive regulatory burden.

More importantly, the regulatory burden hits small businesses the hardest. The cost of government regulation for businesses with fewer than five employees was five times higher than the cost for businesses with 100 or more employees. This is because larger businesses can spread the regulatory burden across a greater number of employees and often have in-house resources devoted to compliance.

Beyond the burden of time and money, excessive regulation creates frustration. It might take two hours to understand confusing language on a form and get an answer from a government helpline and then another two hours for your blood pressure to come down. It's no surprise that 87% of small business owners say that excessive regulation adds significant stress to their lives and that 63% would not advise their children to start a business, given the current burden of regulation in Canada.

Further, 81% agree that excessive government regulation reduces their business's productivity and ability to grow. If regulatory costs on their business were reduced, small businesses would use that extra time and money to increase wages, invest in new equipment and dedicate more time to employee training—all of which are key to growing productivity.

We have identified a number of specific examples of excessive regulations at the federal level that need attention, including things like the disability tax credit forms, T4 dental care and UHT reporting, CBSA classifications, airline fitness for travel forms, interprovincial trade barriers like the movement of food across borders and many more. I'm happy to elaborate on any of those if needed.

We can try to fix every specific regulatory issue that arises, but this will never fix the overall regulatory burden, so a broader approach is also needed. Over the years, we have learned that there are three essential ingredients to effective regulatory modernization.

The first is political leadership. Effective and sustained regulatory reform must be driven from the top, with a political commitment from the leadership that is echoed through all departments and agencies.

The second is regulatory accountability. Regulation deserves the same level of transparency and debate as taxing and spending. Real regulatory accountability requires ongoing measurement and external oversight. To do this, governments need to look at the regulatory burden found not only in regulations but also in legislation, policies and forms. Additionally, governments should measure that burden from all government departments, agencies and delegated authorities to obtain a comprehensive measure and then publicly report on that measure on a regular basis.

The third is constraints on regulators. Perhaps the most effective element in achieving regulatory modernization is imposing constraints on the regulators themselves. Implementing a cap on regulatory costs can ensure that the burden of regulations is kept in check. It also forces regulators to consider alternatives and trade-offs, and to prioritize those regulations that are most important. A regulatory cap could take the form of a reduction target or a target for no net increase in regulatory activity.

The current federal one-for-one rule—whereby one regulation of equal burden must be eliminated for every new one introduced—is a good example of this. However, the federal approach is too narrow and too complicated.

We would also suggest that government continue to work on a few other regulatory modernization best practices.

First of all, make plain language a priority. It is reasonable to expect government to provide consistent, timely advice in plain language.

Another is to introduce a virtual suggestion box, which would allow citizens to flag red tape examples for government.

Next, keep compliance flexible and provide basic guidelines for what constitutes compliance. Regulations really work best when they are outcome-based rather than prescriptive. This allows businesses to find the most cost-effective way to comply with the rules. However, smaller businesses do not typically have the resources to explore different options for the least costly way to comply. For those businesses, having basic guidelines regarding what constitutes compliance is extremely important.

The fourth is to improve online options. Being able to do things online can save a lot of time, but it's also important that online options provide clear pathways to a live person when needed.

The last one is to improve the accountability of regulators by instituting measures like reverse onus guidelines. Often there is little or no flexibility for business owners when it comes to meeting their compliance obligations. However, regulators usually have no specific timelines imposed on them for when decisions will be made or paperwork will be approved. These imbalances should be remedied so that regulators also have deadlines and suffer consequences when deadlines are not met or if advice proves inaccurate or inconsistent.

Thanks for the opportunity to share our thoughts, and I look forward to your questions.

[The Chair, Conservative, Kelly McCauley]

Thank you.

Mr. Swance, you have the floor.

[Chad Swance, Director, Canadian Association of Importers and Exporters]

Thank you.

IE Canada serves businesses that depend on the movement of goods across Canada's international borders. We have over 85 years of experience bringing industry and government together for collaborative decision-making.

I'm joined by Keith Mussar, the vice-president of regulatory affairs at IE Canada and a member of Treasury Board's external advisory council on regulatory competitiveness.

A decade ago, I was starting a new role. The VP came out of his office and said something along the lines of “Per my note, let's go decide on our annual goals.” The whole team went into the boardroom. He dismissed the first person, and after the second person spoke, the visibly uncomfortable VP stood up, announced the annual targets and abruptly ended the meeting. The conclusion was decided before the beginning.

Here's the deal. His team had loftier goals and a plan to accomplish them. He could have looked like a hero, but he simply refused to listen.

Many consultations executed by the Government of Canada have the same outcome. The structure of the consultation is perfectly manipulated to ensure that the feedback it receives is exactly what it wants to hear. In social media, we call this an echo chamber. We only follow accounts that reconfirm our biases each and every day.

We will never get to a modernized regulatory environment without engaging the regulated party.

On the American televison drama The West Wing, C.J. Cregg, the press secretary, often laments about “take out the trash” Friday, when unfavourable stories are dumped. She fears that the administration has become too skilled. We notice that there's a substantial spike in formal consultations around December, July and August. Perhaps it's a similar phenomenon.

How does an ineffective regulation enter into force? It is dumped in the summer, presented to like-minded special interest groups for their echo of approval and then presented to industry as their newest piece of red tape to wrap themselves up in.

IE Canada believes it's time to take a new approach.

In 2019 I had the privilege of working with IE Canada on a proposal that would not only eliminate ineffective regulations but propose a structure to ensure that no new unnecessary regulations would be implemented. The proposal is included in our written submission today.

Our proposal is modelled after the U.S.A.'s Border Interagency Executive Council, which was initiated under President Obama and continued under President Trump. Our proposed Canadian interagency border council would be responsible for vetting all existing and proposed regulations that could impact Canada's border. The best part of this proposal is that the regulators would be forced to sit down and have meaningful conversations with the regulated stakeholders.

Industry representatives must have a substantive role and voice at a border council table, with a structure that ensures that the regulators can regulate. Impacted government departments would be forced to justify in writing why they choose to diverge from industry's recommendations. The border council would radically improve Canada's competitiveness while reducing the regulatory cycle and budgetary outlays.

Just like the employees of the uncomfortable VP, industry stakeholders would not only have aligned goals with the government at the border; they would also have the tools and the data to make the goals a reality. Through a collaborative border council, Canada could improve our global competitiveness in an ever-shifting geopolitical world.

Thank you for your time today.

[The Chair, Conservative, Kelly McCauley]

Thank you very much.

Mr. Greco, please go ahead, sir.

[Alex Greco, Senior Director, Manufacturing and Value Chains, Canadian Chamber of Commerce]

Thank you, Mr. Chair.

Mr. Chair and honourable members, it is a pleasure to appear before you on behalf of 400 chambers of commerce and boards of trade and more than 200,000 businesses of all sizes from all sectors of the economy and from every part of the country.

It will come as no surprise that the regulatory burden continues to be a growing concern for Canadian business. The World Bank's “Ease of Doing Business” report ranked Canada as 23rd in 2020, but we were fourth in the world as recently as 2006. A big part of this decline is we are now ranked 53rd for the burden of government regulation on business. Regulation is literally stifling our economy.

It goes without saying that the right policy environment can help businesses succeed and generate long-term economic growth for the country. Making Canada an attractive destination for business investment that supports economic growth requires getting the fundamentals right.

At a time when inflation is persistent, government and the private sector must look at new ways to make Canada more competitive. Governments in the past have attempted to regulate our industries into a more competitive frame, but this has had the opposite effect, as the costs of starting and growing a business have become a disincentive to investment.

The regulatory burden is troublesome in several ways, but two stand out.

First, we can’t continue to move at a snail’s pace; we need the government to be more ambitious. We need the government to accelerate modernization and ensure that approvals and permitting can meet our public policy ambition.

Second, the ongoing struggle for companies to comply with complex regulations is increasing operating costs. These are consistently one of the biggest barriers to economic growth. According to the “SME Regulatory Compliance Cost Report”, the total regulatory compliance cost to small businesses was nearly $5 billion in 2011, which at the time was approximately $3,500 per business. That number has no doubt increased over the past decade, along with the regulatory burden overall.

We cannot afford for more private sector investment decisions to be sidelined because of the complex regulatory environment in Canada. Too often, we hear from our members about the investments they have on hold while they wait for direction from the government. Lack of clarity and speed on the new investment tax credits is a good example. While other jurisdictions, such as the United States, move quickly to create the conditions for investment, Canada is falling behind.

Complying with a complex network of overlapping regulations with all levels of government is expensive and time-consuming. When combined with inefficient and unpredictable regulatory processes, this sets all businesses up for failure. While I commend the government for pushing a regulatory modernization agenda, we must move more boldly and urgently.

In the time remaining, I would like to focus on three recommendations.

First, the government must move to implement an economic and competitiveness mandate to federal regulators. Too often, regulators do not fully consider economic impacts on business when making decisions.

Second is regulatory alignment across domestic and international jurisdictions. When regulations are more consistent across jurisdictions, businesses are better able to trade within Canada and beyond. Quite simply, we should not require a free trade agreement within our own country. Unless the government actively works to improve collaboration and alignment to ensure businesses are not at a disadvantage, we will see less innovation, fewer choices and higher prices. An example of this is when each province establishes its own framework for regulating pesticides or rules for the trucking of goods across jurisdictions.

Finally, the government should pledge to provide regulatory certainty for businesses. Evidence-based regulations can both protect the public interest and promote market success. For companies looking to invest billions of dollars in developing new pipelines, new mines or other large-scale infrastructure projects, this is a must-have.

In closing, I will say that Canada needs smarter regulatory systems, better processes and well-designed regulations to help minimize the cost of business and unlock economic growth while improving public health and safety outcomes.

Sustained collaboration with all levels of government and our international partners will make it easier for businesses to do what they do best—produce.

Thank you.

[The Chair, Conservative, Kelly McCauley]

Thank you very much.

We'll start our six minute rounds with Ms. Kusie. Please go ahead.

[Stephanie Kusie, Conservative, Calgary Midnapore, AB]

Thank you very much, Mr. Chair.

Thank you very much to all of our witnesses for being here.

I see a lot of friends on the witness stand today, and it's a pleasure to have all of you with me.

I'm looking at a March 22, 2023, article that indicates that small businesses had paid, at that time, a total of $22 billion in federal carbon tax. I'm also looking at a February 20, 2024, article that indicates the federal government scaled back its carbon tax rebates for small businesses and in fact owed small businesses $2.5 billion in promised carbon tax revenues, which, as of the date of this article, had not been returned to small businesses.

Ms. Pohlmann, I recognize that your organization estimates that small businesses contribute as much as 40% of the government's overall carbon price revenue, even though data from your organization indicates that 52% of small firms oppose carbon pricing, and that as a result of this carbon pricing, they're being forced to raise prices for consumers.

Further, more than four in 10 businesses, or 45%, said carbon pricing will increase pressure on them to freeze or cut salaries and wages, something that parties in this room would supposedly like to see maintained or improved, and 40% say they will have to reduce investment in their businesses.

We know that this government likes to perpetuate the lie that the carbon tax is even revenue neutral, never mind that families are losing funds as a result of this carbon tax, as was evidenced by testimony of the Parliamentary Budget Officer to that effect.

Ms. Pohlmann, would you agree that this is also not true for small businesses in Canada? Would you agree that they are in fact losing money due to the carbon tax, and that they are in fact owed money by this federal government? Would you agree that these cuts to the carbon tax should not be implemented, because of the $22 billion that has already been collected, and the $2.5 billion promised back to them that they have yet to receive? Can you comment on that, please, Ms. Pohlmann?

[Corinne Pohlmann]

Yes. We've certainly been very vocal about the fact that the $2.5 billion that has been sitting with the government since 2019 is owed back to small businesses, and it is only a fraction, based on about 8% or 9% of the total revenues coming in.

As you stated, our calculations are that closer to 40% of the revenues that come from small businesses make up carbon revenues in the provinces in which the carbon tax exists. We believe they have just lowered the amount they're going to provide to small businesses from 9% to 5% and will give it to other groups for a variety of reasons.

It has become a real drag for many small business owners, who are right now feeling the pinch and are not feeling that they're necessarily being considered when it comes to the carbon tax, even though they pay a lot of it.

We're hoping to see some movement on that shortly.

[Stephanie Kusie, Conservative, Calgary Midnapore, AB]

I think “a real drag” is an understatement.

I'm very proud to come from a small business family. I know about the stress around the dinner table after the store has a bad day. I can't imagine the stress the carbon tax is placing on all of these millions of Canadians.

We know this government has not been a friend to small businesses. One example is the 2017 tax changes they attempted to implement; this is just another example of that.

Mr. Greco, you said in your opening statement that according to the “SME Regulatory Compliance Cost Report”, the total regulatory compliance cost to small businesses was nearly $5 billion in 2011, which at the time was approximately $3,500 per business. Do you have any idea how much of that would have been carbon tax-related?

[Alex Greco]

I don't have any idea, Ms. Kusie, but I can say that those compliance costs are the result of different requirements and processes in different jurisdictions. The fact that it takes a lot of our SME members over a year or two just to be able to get a permit creates a hindrance to their ability to do business.

From our perspective, that ties into that fact that we're not getting things built or done in Canada, and if we're not getting things built or done in Canada, then we're not spurring economic growth.

From our standpoint, that requires something that ties into my earlier remarks. We need ambition in order to drive economic growth. Ambition without action, from our perspective, leads to empty economic promises, and we won't reverse our investment trends.

We're second-worst in the OECD in terms of business investment. We're near the bottom in terms of research and development. That all adds to the fact that if we don't have a proper level playing field for businesses to succeed, we won't be able to reduce the costs of doing business and we won't support innovation.

[Stephanie Kusie, Conservative, Calgary Midnapore, AB]

Mr. Greer, do you have any comments to add on behalf of Canadian Manufacturers and Exporters about the effect of the carbon tax on the people you represent?

[Ryan Greer]

I would just add that manufacturers are generally facing a very high-cost, high-pressure environment at the moment. It's cumulative, so it is certainly taxes, as we're discussing here today, and the regulatory burden and all the costs identified and maybe not captured in federal processes.

There is certainly the issue of incentives for manufacturing investment and the pressures coming from the U.S. due to the Inflation Reduction Act, not to mention the fact that inflation also impacts all of the inputs that manufacturers require to produce products. It's a very challenging environment for manufacturers, and it's really all of those factors that are driving anxiety in the industrial sector.

[Stephanie Kusie, Conservative, Calgary Midnapore, AB]

Mr. Swance, do you have anything to add as my time comes to a close in 15 seconds?

[Chad Swance]

I think the piece on the carbon tax is to ensure that Canadian companies have a competitive footing in the world in a global economy. Not all jurisdictions have such a tax. How are Canadians being equally treated in a global economy? That's really one of the big pieces around regulations that impact trade: How do we justify an internal regulation that makes us uncompetitive on the global stage?

[Stephanie Kusie, Conservative, Calgary Midnapore, AB]

Indeed, we have telling testimony from families and small businesses, Mr. Chair.

Thank you all.

[The Chair, Conservative, Kelly McCauley]

Thank you very much.

Mr. Kusmierczyk, please go ahead, sir.

[Irek Kusmierczyk, Liberal, Windsor—Tecumseh, ON]

Thank you, Mr. Chair.

I thank you all for being here today.

You just heard from one of the apostles of the do-nothing Conservatives on climate change, but I want to provide you with a different perspective.

I want to especially thank you, Mr. Greer, for being here today, representing the Canadian Manufacturers and Exporters.

In my home town of Windsor, there's a saying: “If you want it built right, build it in Windsor.” We have a lot of manufacturers in our community. It's a huge part of our prosperity in our community and of our economy, so I want to say thank you for your tremendous advocacy.

You mentioned the investment tax credit. I read the “Manufacturing Canada's Future” report, and it highlighted the importance of the investment tax credits for helping manufacturers transition to a zero-emissions clean economy.

How important are the investment tax credits that are contained in our federal government's Bill C-59?

[Ryan Greer]

After the Inflation Reduction Act was unveiled in the U.S., we very quickly began advocating strongly for Canada to take appropriate actions on investments in building the clean, net-zero economy so that it doesn't all happen south of the border. The evidence of the impacts of the IRA are starting to show themselves. I think that factory construction starts are up 70-some per cent year over year in the United States, so they are attracting a lot of investment.

We were pleased to see the investment tax credit decisions that were announced through budget 2023, and we really now are focusing our efforts—and hoping the government focuses its effort—on accelerating the implementation of them. We have some timelines attached to them, but there's still a lot of guidance and implementation information that manufacturers don't have, which slows, or in some cases delays, investment decisions.

We were pleased to see the ITCs that have been proposed so far, and we're now waiting for final guidance on implementation so that investment decisions can start being made.

[Irek Kusmierczyk, Liberal, Windsor—Tecumseh, ON]

Mr. Greer, I hear you loud and clear. The ITCs are vital to manufacturing, to jobs and to manufacturers. The Conservatives are holding up Bill C-59 at committee. They are delaying, obstructing, holding up, this vital piece of legislation that contains the ITCs.

Can you tell us what that delay and Conservative obstruction is costing and risking to Canadian manufacturers?

[Ryan Greer]

We've been long urging, and will continue to urge, swift implementation of all ITC-related measures, both legislative and on the guidance side. The government just finished some consultations on a lot of the guidance for some of the ITCs, and that rests with ISED and other relevant departments and the finance department.

Yes, we 100% encourage swift adoption of all legislative measures to implement the ITCs. However, equally, we're also very concerned that the guidance and implementation information that is needed has not been made public yet, so no investments can start being made.

[Irek Kusmierczyk, Liberal, Windsor—Tecumseh, ON]

Thank you so much for that, Mr. Greer.

Ms. Pohlmann, I want to reassure you that our government remains absolutely committed to the carbon rebate program for small businesses, which will return billions of dollars to small businesses. I want to reassure you and the members that we are absolutely committed to supporting small businesses and returning that funding to small businesses.

The Library of Parliament provided a table, a report, that listed the one-for-one rule implementation over the last 11 years, both under the Conservative government and under the Liberal government. The top four years for reducing regulations—the top four years—in the last 11 years happened under this Liberal government.

We know that there's more work to be done. I want to ask you this: If there's one set of regulations or one sector that you would focus on, what would it be?

This is a question not just for you, Ms. Pohlmann, but also for all the folks around the table as well. Is there a particular regulation or a particular sector that you would focus on?

[Corinne Pohlmann]

That's a tough question to answer, because, frankly, if you start to pick who gets targeted.... I know some of that work has already been done, and it's been interesting work. For example, transportation, or whatever, has been targeted to go through some regulatory modernization initiatives. The problem is that it hits every business. It's a good idea to focus on very specific areas, but you also have to focus on the big picture. Sometimes the big picture is depending on this one act from 2015 that hasn't really moved or changed much. It's a bit narrow and it needs to be broadened out.

For example, the one-for-one rule that currently exists is still implemented and is still being used. It really just focuses on the regulations; yet, increasingly, rules that affect businesses and citizens come in legislation, policies and guidelines. Those are not included.

We don't know, frankly, how many rules are actually out there. Anything that requires a business or an individual to do something needs to be incorporated and thought about as part of the overall picture of how we get a handle on what those rules are in Canada.