Thank you very much.
Distinguished members of this committee, on behalf of director Mario Harel, president of the Canadian Association of Chiefs of Police, I am pleased today to be given the opportunity to meet with you. In addition to my role as deputy chief of the Abbotsford Police Department, I am chair of the CACP drug advisory committee. I am joined by York regional deputy police chief, Thomas Carrique, who is chair of the organized crime committee, and Lara Malashenko, a member of the CACP law amendments committee and legal counsel for the Ottawa Police Service.
The mandate of the CACP is safety and security for all Canadians through innovative police leadership. This mandate is accomplished through the activities and special projects of some 20 CACP committees and through active liaison with various levels of government. Ensuring the safety of our citizens and our communities is central to the mission of our membership and their police services. Bill C-45 is a comprehensive bill, and we will address it from a high level in our opening statement. In addition to our appearance today, we are providing you with a detailed written brief for your consideration.
Our role from the beginning has been to share our expertise with the government to help mitigate the impact of this legislation on public safety. Extensive discussions within the CACP membership and various committees form the basis of our advice. We participated in a number of government-held consultations and provided a submission to the federal task force. We produced two discussion papers, entitled “CACP: Recommendations of the Task Force on Cannabis Legalization and Regulation” on February 8, 2017, and “Government Introduces Legislation to Legalize Cannabis” on April 28, 2017. Themes from both discussion papers have been included in our written brief.
Police leadership across Canada identified seven key themes specific to this bill that impact policing. These are: training and the impact on police resourcing, personal cultivation and possession, organized crime, medical marijuana, packaging and labelling, return of property, and youth and public education. Police leadership also identified that drug-impaired driving and our ability to effectively manage it will impact policing. However, we will leave this theme to be addressed under Bill C-46.
We would like to acknowledge the announcement made by the federal government on September 8, 2017 with respect to the allocation of funding. We are interested in learning the details related to the distribution of funds dedicated to our federal, provincial, and municipal police resources. We wish to emphasize that administering police services requires the necessary training, tools, and technology to assist with addressing public safety concerns, and disrupting the involvement of organized crime in the illicit cannabis market.
In order to support the successful implementation of this comprehensive legislation, the CACP urges the Government of Canada to first consider extending the July 2018 commencement date to allow police services to obtain sufficient resources and proper training, both of which are critical to the successful implementation of the proposed cannabis act. Second, we ask that an established legislative framework be put in place prior to legalization that will provide law enforcement with clear direction and assistance regarding funding and training. Third, provide sufficient detail to allow law enforcement to assess the availability of funding, recognizing the need for a more standardized and consistent approach among provinces and territories, vis-à-vis the implementation of police resources necessary for the legalization of marijuana, and the need to obtain further guidance regarding the training of front-line officers, which would include plant seizure and identification of illicit cannabis. Fourth, increase funding for public education and youth programs and the issuance of tickets under the ticketing provisions of the act. Fifth, due to the foreseeable concerns surrounding personal cultivation and enforcement, we ask the provisions permitting adults to grow up to four marijuana plants be revoked. The CACP predicts that these provisions would be problematic to enforce, would provide additional opportunities for the illegal sale of marijuana, and would pose a further risk to youth due to increased exposure and accessibility.
We were pleased to see in the September 8, 2017 announcement that Finance Canada will consult on a new tax regime on cannabis. This is critically important because, despite the proposed cannabis act, organized crime will continue to look for opportunities to exploit the market and to profit. We will continue to advocate that the cost of legal cannabis remain as low, or lower, than cannabis sold on the black market in order to discourage price undercutting and illicit sales. We would also ask the federal government to enact strict security clearance requirements, which would ensure that criminal organizations do not become involved as licensed growers, which has been observed under the medical regime.
Police agencies must prioritize drug investigations on the basis of public safety. It is well documented that many police agencies are currently concentrating on the opioids that are responsible for an unprecedented number of overdose deaths. However, it is important, as we move to a regulated regime for cannabis, to recognize that strict enforcement is necessary at the onset to protect youth and help disrupt organized crime.
While the commitment made on September 8 to provide funding to policing to enforce a proposed cannabis act is positive, questions still remain in regard to how this money will be allocated. We wish to reiterate that dedicated police cannabis enforcement teams are necessary to disrupt organized crime and keep cannabis out of the hands of our youth.
Given the infiltration of organized crime into the medical marijuana industry, the CACP recommends merging the cannabis act with the access to cannabis for medical purposes regulations to avoid confusion, to align the efforts of Health Canada and law enforcement agencies, and to limit organized crime activity by reducing the number of licensed producers and distributors.
The CACP recommends that packaging requirements be stringent, in order to provide clear labelling to allow police to identify between legal and illegal cannabis, and to give users adequate information to make informed choices about their cannabis consumption. We further recommend that labelling include notice regarding penalties for providing cannabis to youth as a further protection mechanism and deterrent.
The CACP has concerns regarding the return of property provisions that appear to require the police to maintain and return seized cannabis plants. Police services across Canada do not have the facilities or resources to accomplish this. Accordingly, we ask the act to address these concerns by relieving police services of any responsibility associated with the deterioration of seized cannabis plants or having to provide compensation.
Lastly, there should be a continued focus on protecting youth through education and other non-Criminal Code means. The cannabis act, for example, will permit youth to possess or social-share five grams or less, which is inconsistent with the bill's intended objectives. Examples from Colorado and Washington have demonstrated that legalization may encourage increased marijuana consumption among youth. Therefore, police-driven education on the effects of marijuana use is critical to discourage consumption by youth.
Our recommendations are not intended to dispute the government's intention of restricting, regulating, and legalizing cannabis use in Canada. Instead, we bring these issues forward because the answers remain unknown. We are concerned about the impact of this act and, as previously stated, we have the responsibility to mitigate the impact on public safety, which is our primary goal from a policing perspective.
We certainly commend the government for its commitment to consultation with stakeholders and the public. We also commend the efforts of ministers, parliamentarians, and public servants who are dedicated to bring forward the most comprehensive legislation with a mutual goal of putting forward a responsible framework prior to legalization and recognizing that the world is watching Canada throughout this process.
In the interests of public safety and preserving the quality of life that we are fortunate to enjoy in Canada, we appreciate the opportunity to share our crime prevention and law enforcement experience with the government. We recognize that illicit drugs are a global issue that dramatically affects local communities, families, and individuals. As the world watches Canada throughout this complex process, we are committed to working with the government and the Canadian public to ensure that comprehensive regulations that mitigate the public safety concerns associated with cannabis are established prior to legalization. We support many of the overall goals of the act while recognizing that other stakeholders are better equipped to provide specialized knowledge in the area of public health and in social services. We also support efforts to deter and reduce criminal activity by imposing serious criminal penalties for those breaking the law, especially those who import and export cannabis and who provide cannabis to youth.
Sincere thanks are extended to all members of this committee for allowing the Canadian Association of Chiefs of Police the opportunity to offer comment and suggestions on Bill C-45. We look forward to answering your questions.
Thank you.