Citizenship and Immigration Committee on Dec. 2nd, 2025

[Nicole Guthrie, Barrister and Solicitor, Legal Assistance of Windsor]

Good afternoon, Madam Chair.

I'm going to be speaking about the immigration levels. While we can understand the importance of monitoring immigration levels for any society—and measures to reduce immigration levels are important for any country—we would suggest that Canada is a vast country that depends on immigrants at every level to sustain the workforce, economy and demographics of the country.

I deal with many migrant workers. We understand that agriculture has evolved and grown over time, with an expansion in the temporary foreign worker program to sustain greenhouses in other areas of the country. That is very important.

Giving the minister broad powers to stop or cancel entire groups of applications to extend processing time creates uncertainty because of delays and misunderstanding. It's harmful, and it denies applicants the ability to be heard. It's also harmful because it creates uncertainty and contradicts basic human rights and international and Canadian principles around law and procedural fairness.

We are concerned that this ability to extend processing time and reduce immigration levels has a significant effect on temporary foreign workers. There are significant numbers of workers in Canada who are looking for ways to remain in the country temporarily. They have been here a long time, and they have applied for status. We have seen that this reduction in numbers or reduction in immigration levels can impact certain demographics, especially those under the temporary foreign worker program who come from varied backgrounds, especially from Latin America, the Caribbean and other Asian countries.

We would suggest that from a political perspective, measures to reduce immigration levels may be more viable in countries with very large populations. However, they are not suited for Canada because of the impact they will have on the skilled temporary foreign workers, among other categories of applicants in the country.

Any type of reduction in immigration levels will conflict with refugee and immigration law, particularly the 1951 refugee convention and its 1967 protocol. There are many important decisions made by the Supreme Court that emphasize the impact of international law and domestic law, especially in the context of human rights.

The article entitled “The Domestic Application of International Law in Canada” claims:

But the Supreme Court of Canada has developed this tradition by insisting that international law is part of the context in which Canada’s domestic laws are enacted.

For instance, in the famous case of Baker v. Canada, the Supreme Court emphasized that courts should take into account the regulations of international law, especially regarding human rights, and the administration should act in accordance with these norms.

In addition, the Supreme Court emphasized that while Canada must comply with international rights, the government should ensure that the rights of persons in Canada are respected and upheld.

To conclude, we would emphasize that allowing these levels to be reduced and processing time to be expanded will weaken due process and independent oversight. Any expansion of cancellation powers for IRCC, rigid documentation rules and expanded data sharing, especially with CBSA, will lead to wrongful refusal, have a desperate impact on vulnerable groups and lead to a higher risk of refoulement.

[The Chair, Liberal, Julie Dzerowicz]

Thank you, Ms. Guthrie. You may continue, probably in the answers, to give the rest of your testimony.

Now we go to Mr. Brown for five minutes.

[Alexander Brown, Director, National Citizens Coalition]

Thank you, members of the committee.

My name is Alexander Brown, and I am the director of the National Citizens Coalition, which is one of Canada's pioneering non-profit advocacy groups.

Today, there are few issues that animate Canadians more than immigration—a system that worked all but seamlessly into the 2010s. David Coletto of Abacus Data presently has it as the number four pocketbook issue for young Canadians and number six overall.

In a recent study from Environics, a majority of Canadians continue to say that there is too much immigration. Those who express this view increasingly point to poor government management as the problem there. In a recent poll from Leger, most immigrants want fewer than 300,000 immigrants annually. This is lower than outlined in the budget.

It's not hard to see why that concern isn't going away. Our revised immigration plan doesn't solve for a sudden overcapacity problem. What we have in land, we lack in basics. There were 500,000 Canadians who walked out of emergency rooms last year without receiving care. That's data from CBC's Marketplace. That's 5% to 15% of all ER attendees.

One in five Canadians is without a family doctor, according to the latest from Angus Reid. This is a major concern to the Canadian Cancer Society, which partnered on that poll. In additional recent analysis, the think tank Second Street has north of 23,000 Canadians dying on wait-lists over the past year.

The youth unemployment rate reached 15% in September, according to StatsCan. That's the highest level since 2010, excluding the pandemic years. Over the summer in Toronto, youth unemployment cracked 20%.

According to the CMHC, 2025 is on track to set a 30-year low in housing starts.

I open with facts and figures—with what all the requisite experts say—because we need to avoid disqualifiers and excuses. We need to get this fixed. To borrow from a terrific Jamie Sarkonak column, “Turning down the taps won't un-flood the basement”. All we've done is turn down the taps.

On the temporary foreign worker and international mobility programs front, I and immigration expert Dr. Michael Bonner—he's spoken to this committee and he once worked in service on this file under Stephen Harper and Jason Kenney—argued in The Hub, “It wouldn’t be wrong to view these programs as distortionary government subsidies or welfare for unproductive businesses.” The effects disproportionately harm younger Canadians, who are priced out of the labour market, given that temporary workers overwhelmingly earn less than the median wage, yet we're constantly hectored about labour shortages and Canadians' unwillingness to do certain jobs.

It shouldn't take much intellectual effort to see that the use of foreign labour and the difficulties of employing younger Canadians are two sides of the same ugly coin. Foreign workers are more co-operative, because they are bound to their employers like serfs and face barriers to joining unions. The UN branded our abuse of those programs as a contemporary form of modern slavery for a reason. Downstream from that grotesquerie, our domestic population struggles.

If you have young people in your lives, or if you talk to students when they visit you on the Hill, they're sending out hundreds of résumés and going nowhere right now. That means they're securing stable income later, struggling below the mean or having children later. They're unable to afford homes and down payments. We're extending their adolescence, and it's in large part due to blowing the doors off our inflow as of 2021 to grow in numbers but not productivity.

The NCC, in its “Canadians for responsible immigration” campaign, is calling for the following.

Abolish the temporary foreign worker program for all but the hardest-to-fill roles. I understand that seasonal agriculture, construction and engineering are important. If you need it, sure.

Add safeguards to prevent the diploma-mill eruption—witness post 2020—so it does not happen again.

Close asylum loopholes. The system is out of control.

Lower permanent residency targets further, strengthen deportation policies, prioritize high-value students and reform the points system.

I close with this quickly. Our immigration system has never been set by our business lobby. When you go to a barber and ask them if you need a haircut, what do you expect them to say? For everyone in your ear right now telling you they want to return to the moon shot of the last few years, or who want to amnesty as many from the COVID wave as possible, I implore you to say no. Say no for the students and grads sending out hundreds of résumés. Say no for the 15 foreign students who were sold a lie and are living in a basement, sharing a single washroom.

Canadians are telling you they want even more change to responsible immigration. They want better targets and a clear exit strategy for those set to expire. Will we listen?

[The Chair, Liberal, Julie Dzerowicz]

Thank you so much, Mr. Brown.

Mr. Toupin, I invite you to give your opening remarks. You have the floor for five minutes.

[Jean-Denis Toupin, Engineer, M. Eng., Proco Group Inc.]

Ladies and gentlemen, thank you for inviting me to appear before you.

I'm here to represent the Proco Group and Alliage 02, a group of 300 manufacturing companies operating in Saguenay—Lac-Saint-Jean, a region with a population of 280,000, located 250 kilometres north of Quebec City.

My purpose is simple: to show the importance of temporary foreign workers to Canada's manufacturing sector, especially in the regions, and to explain the major negative economic impact of the new restrictions that currently affect them.

Proco Group is a construction company founded in Saint-Nazaire over 40 years ago. It includes four companies that specialize in steel structure manufacturing and installation. We currently have about 500 employees and our sales amount to $163 million.

Our projects include public and industrial infrastructure across Canada, such as bridges, ports, hydroelectric power plants, buildings and mines, from Quebec to Nunavut. In the past four years, we've invested over $18 million in capital expenditures, automation and robotics. If the labour situation stabilizes, we plan to invest another $10 million.

Under current conditions, these investments have become impossible because the workforce in our plants is disappearing. In fact, Quebec's unemployment rate is one of the lowest in Canada, and in Saguenay—Lac-Saint-Jean the rate is even lower, at around 4%. The unemployment rate for welders in our region is practically 0%.

Obviously, we exhausted all of our local resources before turning to immigration. The shortage of skilled workers in Saguenay—Lac-Saint-Jean is very real. A recent survey showed that over 160 of the region's businesses currently employ 2,372 temporary foreign workers, or TFWs.

The new rules are forcing more than 500 of them to leave the country. Since 2019, we've hired 77 TFWs, and 60 of them are still with us. They earn from $26.75 to $38 an hour. We've invested over $1.2 million in TFW reception costs, which include housing, training and integration. TFWs currently represent 47% of our production capacity, or 45 out of 95 welders. In January 2025, we already had to give up 17 TFWs. The new rules will cost us another 30 jobs in the next two years. These losses are impossible to offset locally.

In its latest budget, the federal government said that it would consider essential industries, like construction, and regional realities. So far, nothing has been done for us, for the manufacturers, and we're already incurring losses. The consequences are severe: lost production capacity, increased manufacturing costs, lost strategic construction contracts now processed abroad, investments put on hold due to a lack of available operators and the loss of expertise. At the end of the day, this will mean job losses for our Canadian workers.

Why are TFWs essential? Their productivity is outstanding. At Proco, every employee generates $340,000 in annual sales; that's seven times the average gross domestic product, or GDP, per person in Quebec. Without them, operating our two plants would be impossible.

Our region plays a strategic role in Canada. It's the site of military projects, deepwater ports, hydroelectric projects, aluminum plants, mines and rare earths. The rules imposed a year ago, however, are already seriously impeding our ability to meet demand. Worse than that, the high-wage concept is making us less competitive than international manufacturers. As a result, local projects are now being processed abroad.

To maintain Canada's manufacturing competitiveness, here's what we recommend. We have to regionally reinstate the simplified program conditions, grant three-year work permits to make things more predictable for entrepreneurs, adjust wage thresholds to reflect the regional cost of living, immediately introduce a grandfather clause for existing foreign workers and prioritize construction-related manufacturing sectors.

In conclusion, TFWs are, for now, an indispensable solution to the regional labour shortage. They are an economic driver. Structured, regionalized and predictable economic immigration is essential to Canada's manufacturing competitiveness. Without it, we will lose investments, jobs and our ability to deliver strategic projects.

Let me repeat: The new federal TFW measures are reducing Canada's manufacturing capacity and are already affecting hundreds of regional businesses.

With the small amount of time that I have left, I'd like to invite Mr. Brown to come visit Lac-Saint-Jean and see the temporary foreign workers who work in our plants and their working conditions.

[The Chair, Liberal, Julie Dzerowicz]

Mr. Toupin, your time is up.

Thank you. I'm sorry about that.

I want to thank all the witnesses for their testimony.

We will now begin the first round of questions.

The first round is for six minutes. We're going to go to Mr. Davies.

Oh, I'm sorry—we're going to Ms. Rempel Garner.

[Michelle Rempel, Conservative, Calgary Nose Hill, AB]

You're fine. It's okay. Fred is awesome, too.

I'm going to direct my questions to Mr. Brown.

You cited some figures that I think a lot of Canadians are concerned about but that haven't often been heard at this committee: We have a youth unemployment crisis, and many Canadian youth are seeing that opportunity for a first job evaporate as there has become more of a heavy reliance on temporary foreign workers, be they students with work permits or through various streams of the TFW program.

Is that what you're hearing through your organization as well?

[Alexander Brown]

Yes, very much so.

I was speaking anecdotally at the University of British Columbia last week, and the kids just wanted to talk about the hundreds of résumés they're sending out that are going absolutely nowhere.

We have an obvious issue, and I understand the need and appreciate the comments in the previous testimony, but former Bank of Canada governor David Dodge warned us that the last thing we want is a bunch of low-productivity businesses hanging on because we provide them cheap labour. Not only is it bad for Canadian productivity, but there's also a big risk that it will contribute to wage suppression and job displacement for Canadian workers.

The TFW program is failing the grade on multiple different sets of conditions. It is drawing the ire of international rights organizations. There was a recent report that came out as well—

[Michelle Rempel, Conservative, Calgary Nose Hill, AB]

I hate doing this, but I have a very short period of time, so keeping your answers quick helps me out, too.

[Alexander Brown]

I see. Real quick, then, the Investigative Journalism Bureau—

[Michelle Rempel, Conservative, Calgary Nose Hill, AB]

No, I'm going now. That's how it works.

[Alexander Brown]

I see.

[Michelle Rempel, Conservative, Calgary Nose Hill, AB]

We have had testimony on this panel, which I sympathize with. There are regions in the country where there is a need for labour.

Rather than asking how we indefinitely continue to juice the supply of temporary labour while we have a youth jobs crisis, why aren't the government and industry working together to, maybe over a period of a few years, look at labour mobility strategies and youth training strategies, so that in economic regions where there is a need for labour, we can incent people to move where there are 20% to 25% of youth jobs? Would you recommend that?

[Alexander Brown]

Absolutely. I appreciate the concerns of others, but my concern, first and foremost, is the Canadian workforce, Canadian jobs and our record in continued unemployment. Could we not be putting these resources into upscaling, into training and into working within the provinces too? I'd love for the best in B.C. to be working in Quebec right now. I don't want there to be shortages anywhere, but we have a massive backlog of unemployed young Canadians—of unemployed Canadians—whom we surely need to continue to give the first crack to.

[Michelle Rempel, Conservative, Calgary Nose Hill, AB]

I agree.

We had a labour union leader from British Columbia talk about how people who are coming into the trades to participate in manufacturing—young Canadians—might be in one of their training boot camps, but they can't get hired because of wage depression that's inherent to the TFW program.

You talked a bit about wage suppression. Do you think, over time, that phasing out the TFW program—and I'm talking specifically about economic regions that have high employment—abolishing it and focusing instead on labour mobility and jobs training, specifically for youth in trades, and betting on Canadian kids who are out of work is a better strategy in the long term for Canada's economic productivity and wage equity?

[Alexander Brown]

It's more sustainable, certainly. It'll lead to a healthier economy. It'll give these kids a hand up, because they're failing to launch in record numbers, and I think we all know where that could go. I worry about them socially and where that's going to lead if they're alienated, unemployed and stuck at home.

That has to be the play. We have our economic experts telling us that's what you're supposed to do for a living. We used to pay more, offer more and train more. I hope we return to that, and this doesn't become the new model we rely on.

[Michelle Rempel, Conservative, Calgary Nose Hill, AB]

On that note, I worry because from some of the economic data I've seen, Canada increasingly has an indentured labour underclass. I don't that think that's how immigration was supposed to work in Canada. I think people who come to Canada should be able to fully participate economically, not as a labourer indentured to one company.

Some people will say that we need to open up the TFW program and make it more flexible, but I see a 20% unemployed youth labour force. I think that the first goal should probably be to abolish the TFW program and make sure we're looking not only at economic regions that have special needs but also at more labour mobility and youth training programs.

Would you agree with that recommendation?

[Alexander Brown]

Yes.

We have price-to-income ratios in our country right now that I believe are 10 to 1. If we want to recruit the world's best and brightest, and if we want to bring in those with high skills in our temporary foreign worker program, they're going to need homes, they're going to need doctors and they're going to need incentives.

As it stands, we're inviting people over and it's like we haven't cleaned up the house, the oven's not on, and there's a hole in the air mattress. We have so much to improve, and that starts by doing right by our workforce.

[Michelle Rempel, Conservative, Calgary Nose Hill, AB]

Thank you very much.

[The Chair, Liberal, Julie Dzerowicz]

Thank you, Ms. Rempel Garner and Mr. Brown.

Next, we have Ms. Zahid for six minutes.

[Salma Zahid, Liberal, Scarborough Centre—Don Valley East, ON]

Thank you, Chair.

Thanks to all the witnesses.

Ms. Guthrie, thanks a lot for appearing before the committee. My questions are about the caregiver program.

Caregivers play such an important role in caring for our families and our loved ones. They are skilled workers doing work that we can't find enough Canadians to do here. The government has signalled its intention to move from temporary pilot programs towards a permanent caregiver immigration program in the coming years.

What would the essential pillars of that permanent program need to be in terms of admissions numbers, eligibility criteria and settlement supports, so that Canada can reliably meet our caregiver needs for home child care and also the home support workers program, while treating those workers with fairness, respect and the dignity everyone deserves?

[Nicole Guthrie]

I agree that Canada's temporary foreign workers are essential. I do understand the needs of Canadian workers. However, in the temporary foreign worker program, a large number of foreign workers are in caregiver and other essential categories. In the caregiver program, a lot of the applicants are racialized women from countries in Asia and the Caribbean. In order to make it an equitable, consistent and fair program, Canada needs to specify that temporary foreign workers should have the sector-specific work permit. As my fellow witnesses have mentioned, they should not be tied to one particular employer. We should also ensure that their wages are comparable to other wages in Canada, so that there is fair and equitable treatment of the workers.

I would suggest that the processing times and the application requirements be clear and specific. The current program opens once a year and allows only a certain number of applicants. There is no certainty. There is no consistency. We need to ensure that our workers understand the process when they are entering the country and what is going to happen. That will reduce the chances of their being tied to one specific employer and ensure that they're not open to abuse. It will ensure that there is a predictability and openness in the program. I would suggest that should be how the program be administered.

In terms of numbers, we've seen in previous years that leaving the program on a rolling application basis ensures that everyone is able to apply and that everyone understands the requirements of the program to be able to enter it.

[Salma Zahid, Liberal, Scarborough Centre—Don Valley East, ON]

The last pilot program announced for caregivers was to give them PR on landing. What would you say to that? Should people who are coming here under the caregiver program get PR on landing?

[Nicole Guthrie]

I would suggest that this aspect of the program continues. As long as the applicant meets all the requirements—which was also part of the program—has a sector-specific work permit saying they are allowed to bring their families into Canada and continues to adjust in Canada.... We've seen, in previous versions of the program, a single mother in Canada working without her family members while her children and husband grow old overseas because of processing times.

It is a very good idea to ensure that families stay together. It is a goal of IRPA. The Immigration and Refugee Protection Act wants to ensure that families remain together in Canada. As long as everyone meets the requirements of the program, and as long as the applicant has a sector-specific work permit, so they're not open to abuse, they can continue on and be landed as permanent residents at the end of the program requirements.

[Salma Zahid, Liberal, Scarborough Centre—Don Valley East, ON]

Thank you.

I would like to ask you a question on out-of-status caregivers. These are people who have come to Canada legally, who have been contributing to our economy and paying taxes, and who have fallen out of status only due to paperwork processing delays or some language requirements.

Do you believe there should be amnesty, or a program to bring these people into status? What should that look like?