Thank you for inviting me to address the committee.
By way of background, I am currently the president and CEO of the Business Council of British Columbia. Prior to that, I spent two decades with the Canadian Federation of Independent Business, representing small businesses across Canada.
Regulation has been a career-long interest of mine. I've published numerous studies on it, including one recently for a Harvard journal. I chair the External Advisory Committee on Regulatory Competitiveness, which has a two-year mandate to give external advice to the Treasury Board.
During our work, we heard the consistent theme that there was an urgent need to modernize and improve our regulatory system. I will touch specifically on three ideas that the committee spent time on.
First and most generally, Canada's regulatory system needs a vision or a North Star, and we propose that the North Star be regulatory excellence. The diagram on the slide that I provided shows that it has “protection” on the vertical axis and “burden” on the horizontal axis. The quadrant that we should be shooting for in Canada is the northwest quadrant, which represents high levels of protection while minimizing unnecessary burden. Of course, sometimes people refer to unnecessary burden as red tape.
High protection is important to Canadians. We want to trust that the milk in our fridge is safe to drink. It also gives us an advantage, of course, with foreign buyers. We know that Canadian products, whether we're talking about blueberries or lumber, are valued for their quality, and that includes the high environmental and safety standards that govern their production. That makes them very marketable.
Regulatory excellence serves the public interest by promoting strong protections while minimizing unnecessary burdens that can limit economic opportunities. Reducing unnecessary burden can be hugely beneficial.
We heard one very relevant and compelling example from the Province of Nova Scotia. The province is working to eliminate some of the unnecessary burdens facing doctors. One change they made was to eliminate some of the unneeded requirements around doctors writing sick notes. This one change alone freed up 67,000 hours of time for doctors in the province. That's the equivalent of over 200,000 patient visits. Imagine what a powerhouse Canada could be if we were to get serious about eliminating unnecessary burdens across all of the interactions that governments have with citizens and businesses.
The second idea that the committee spent time on is regulatory measurement. Measurement is foundational to accountability and trust. Canada's regulatory system is in critical need of better measures across the board.
We think that an early focus of this should be a digitized inventory of regulatory requirements, and the good news is that Transport Canada is developing something that could do this job across government. They're developing a searchable database that can do things such as identify regulatory requirements throughout the supply chain. You might want to know, for EV batteries, from mining to manufacturing, how many requirements there are, or maybe you want to know how many different definitions there are for “child” in Canadian legislation and regulation. The answer is that there are 103 definitions for “child” in 107 Canadian acts and regulation. An easy-to-search database would save time and allow for better targeting of areas where burden can be reduced and for understanding areas where more regulation may be needed. Of course, we could also track what's happening to the inventory over time.
The final idea that I want to highlight is consultation and engagement. We believe that we need a culture change from one-and-done consultation to ongoing engagement and continuous improvement throughout the life cycle of regulation. General themes that we heard in our work include the importance of plain language; outreach that starts early; making compliance as simple as possible and creating easier ways for users to provide feedback to the system; and creating and maintaining strong avenues for external advice and feedback, and this could, of course, include a third external advisory committee. We think that outside advice supports momentum and accountability around regulatory excellence.
In conclusion, there are three ideas.
First, regulatory excellence can make Canada more competitive and help with the affordability challenges that are top of mind for households and the productivity emergency that is top of mind for the Bank of Canada. It's an idea that should be championed across government and beyond.
Second, we need better measurement to hold ourselves accountable to the idea of regulatory excellence.
Finally, regulators need to seek outside advice and stay in conversation with those they regulate. The external advisory committee is a good example of that.
Thank you very much.