House of Commons photo

Crucial Fact

  • His favourite word was industry.

Last in Parliament October 2015, as NDP MP for British Columbia Southern Interior (B.C.)

Won his last election, in 2011, with 51% of the vote.

Statements in the House

British Columbia Southern Interior Communities April 28th, 2008

Mr. Speaker, there are many people in my riding who are making a difference in their communities.

First of all, I would like to congratulate Mayor John Dooley and his council for hosting a successful local government conference in Nelson. Thanks also to the mayor for his tireless efforts on behalf of quality child care in my province.

In Osoyoos, I had the honour of attending a gala fundraising dinner sponsored by the Osoyoos Arts Council and I wish it all the best in its future endeavours. In Princeton, I co-sponsored a viewing of the film Tableland on local food security. Thanks to Ann Hughes and others, over 100 subscribers will soon be able to pick up locally grown fruit and vegetables once a month. I would also like to thank all from Kaslo and Oliver who came by our drop-in sessions and to Cindy and others for a tasty lunch in Ainsworth.

Let me close by paying tribute to Nancy Anderson of New Denver, who recently passed away. Nancy was a well respected naturalist, who devoted her life to the environment and the preservation of the cultural heritage in her community. Thanks you Nancy for making our world a better place to live in.

Canadian Environmental Protection Act, 1999 April 28th, 2008

Mr. Speaker, I did not quite get the question that my colleague was going to ask but I believe it had something to do with the cost of food.

It is true that food prices are rising in the world. Biofuels are one reason for this but not the main reason. There are obviously other reasons. I believe if a biofuel policy were looked at--

Canadian Environmental Protection Act, 1999 April 28th, 2008

Yes, Mr. Speaker, I believe we should be looking at other technologies in the area of biofuels, which is why I and my party are saying that we are not against the concept of biofuels. We are questioning the way in which Bill C-33 would implement biofuel production in Canada.

With regard to Canada and the production of food, although we do contribute to food aid in the world, someone recently implored Canada to do more. I believe it was a man who said that Canada was actually not contributing enough, that the current government was not taking the initiative internationally to work with various NGOs and other countries to alleviate the suffering that is being caused by a lack of food.

It has been quite some time since we have reached the goal that was set years ago of 0.7% for international aid. Maybe now, with a food crisis in the world, this is a chance for all parties to really help with the scarcity of food in this world.

Canadian Environmental Protection Act, 1999 April 28th, 2008

Mr. Speaker, it is a pleasure to speak once again to this bill. I just want to say that the amendment that we are proposing, that this bill goes to a special committee to ensure that any regulations or any rules that affect biofuels undergo careful scrutiny, is very important.

This would provide the precautionary approach. It is another safeguard. I did table an amendment in committee that was adopted, which basically stated that within six months after this bill comes into force and every two years after that, there would be a comprehensive review of environmental and economic aspects of biofuel production.

This amendment puts that kind of precautionary approach ahead of this taking place, and my amendment ensures that we really scrutinize the whole use of biofuels in Canada.

I do have a concern that the other amendments that I did propose in committee did not go through, and that is one of the reasons why we are here today debating this bill. I would just like to mention some of the amendments that were rejected.

Had they been accepted, this bill would have prohibited the use of genetically-modified grains, oilseeds or trees for biofuel production, except for those genetically-modified grains, oilseeds or trees that were used for biofuel production in Canada before 2008.

It would have prohibited the use of lands protected by federal legislation and other sensitive biodiverse lands for biofuel production. It would also have preserved the biodiversity of lands used in biofuel production and prohibited the importation of grains or oils for use in biofuel production.

Those were some of the amendments that I had proposed that were rejected. If we look today, we see that apparently Husky Oil, which has a plant in Lloydminster and Minnedosa, is thinking of relying entirely on corn for its ethanol production, thereby not really giving any benefit to the farmers in Manitoba, and opening up the possibility of using corn imported from the United States to fuel these two plants, completely bypassing the primary producer in Canada. I think this is wrong.

If we look at the chain reaction of what is happening, maybe it is oversimplified but this gives us an idea of what is happening in biofuel production in the world, we see that, for example, there is more crop land being turned over to produce corn for biofuels in the United States, at the same time displacing land that has been used traditionally for soybean production, which then increases the acreage for soybean production, for example, in Brazil, which displaces cattle ranching, which then forces the ranchers to cut down the precious rainforest to have grazing land for cattle.

In all of this whole cycle, I cannot see a positive effect on greenhouse gas emissions. That is just one example of what is happening.

We are not opposed to biofuels in general because the concept can be a good one. For example, in my province of British Columbia, there is a company that is now in production utilizing waste from restaurants to produce biodiesel, which is certainly a way of using the oil that normally would be thrown out. So there are ways of harnessing the energy for positive purposes.

What this bill does without any amendments is it gives our Prime Minister and this government basically a blank cheque to implement their proposals for biofuels, which do not take into consideration the negative effects on the environment or the increase in greenhouse gas emissions.

What I would like to do is just focus on a couple of articles that have come across my desk in the last couple of days. One is from the Malaysia Sun, March 23, 2008, and it basically stated that the head of Nestlé, the world's biggest food and beverage company, has sent out a warning against biofuels. The chairman and chief executive of the company said that the growing use of crops such as wheat and corn to make biofuels was putting world food supply in jeopardy. He said that the current subsidies being handed out to biofuel makers were unacceptable while the price of maize, soya and wheat was being driven higher. He also said that land for cultivation and water sources were under threat.

An article in Friday's Ottawa Citizen stated:

It is increasingly difficult to mesh the happy talk about biofuel production in Canada with what is going on in the rest of the world.

The article goes on to state:

Now, food supply is a complex thing. But it's becoming clear biofuel production is playing a role in shrinking that supply.

While the biofuel industry is not the main reason for food prices going up, it is one of the contributing factors, which is all the more reason for us to look at the bill and look at the policy. As we present a policy for the future, we should be looking at the long range effects and not at the immediate short term gains that may or may not be there.

If we look at what has been happening in the United States, we see that something like 58 proposed ethanol plants are on hold now because the Americans are questioning where the industry is leading them. I think we have a golden opportunity in Canada to do this right and if we look at the amendment, and if it is accepted, that will be a positive step in that direction.

Numerous statements have been made by civil societies and others that are questioning the whole direction of biofuel production. I would like to quote from a joint statement by the Tamil Nadu Environment Council and Equations, India, which states:

Demand for water is growing along with the economy. Agrofuel plantations will only increase competition for water, and ultimately impact food resources.

We seek a ban on any scale of monocultures and plantations for the sake of agrofuel production.

That is from an organization in India which emphasizes, from what it says, that maybe we are not going in the right direction.

Another headline from a November 2007 article reads, “An African Call for a Moratorium on Agrofuel Developments”. The article states:

We, the undersigned members of African civil society organisations, as well as organisations from other parts of the world, do urgently call for a moratorium on new agrofuel developments on our continent. We need to protect our food security, forests, water, land rights, farmers and indigenous peoples from the aggressive march of agrofuel developments, which are devouring our land and resources at an unbelievable scale and speed.

We should be looking at that statement as a warning that if we proceed down the road, which our neighbours to the south have in utilizing corn, for example, in the production of ethanol, we can see the tremendous impact that it has on our resources, the environment and on water in particular.

It is not only articles written by civil societies. Scientists and science institutes are questioning this from the scientific point of view. For example, Mr. Robert Watson, scientific advisor to DEFRA and former chair of the IPCC in the United Kingdom, states:

It would obviously be totally insane if we had a policy to try and reduce greenhouse-gas emissions through the use of biofuels that’s actually leading to an increase in the greenhouse gases from biofuels.

Research shows that when we take into account all of the input costs and the transportation, there is actually an increase in greenhouse gases from biofuel production.

I would like to close by quoting from the recommendations of REAP Canada. It is a study called, “Analyzing BioFuel Options: Greenhouse Gas Mitigation Efficiency and Costs”.

The organization made the following recommendations to our committee about Bill C-33:

This bill should be withdrawn for 3 reasons:

1. It won’t appreciably reduce GHG emissions.

2. It is not a “Made in Canada” solution.

3. The legislation does not demonstrate fiscal responsibility.

This is a scientific institute that has studied the whole question of biofuels and it is saying that we should look at this from a precautionary point of view.

I would hope that my colleagues in the House will support--

Committees of the House April 17th, 2008

Mr. Speaker, I would like to point out to my colleague and the previous speaker that in fact it was the New Democratic government in British Columbia that brought in the agricultural land reserve, which since then has been hammered away at by other governments that may favour development.

The fact is that we do have small farmers. I also would like to say that I do represent small farmers in my area, who are being hammered by the meat regulations that our provincial government has imposed, which basically prohibit a farmer from killing and selling meat on and from his or her property. Interestingly enough, this exemption exists in the province of Nova Scotia. This is not the case there. Farmers are allowed to do that.

All of this is a result of the pressure being put on provinces by our federal government and pressure from the World Trade Organization to harmonize. As we do, as we move into this big agricultural industrial model, which favours genetically modified crops and harmonization, it is the small farmer who is suffering. Somehow, then, we have to help sustain our small communities and keep agriculture alive.

Committees of the House April 17th, 2008

Mr. Speaker, one would think it is election time, but my hon. colleague from the agriculture committee read his notes very well, so I would like to thank him for that.

I will answer the question with a question. When I talk about food security in our country and when I say that we appear to be going in the wrong direction, what is he not in agreement with?

There are programs in place, but obviously something is not right if people are losing money and we have a crisis. As I said, we seem to always be reacting to situations rather than trying to have this infrastructure in place.

I also would like to remind the member that as agriculture critic for my party I represent many farmers right across this land, and we talk on a regular basis. That, for example, is why I cannot understand the government continuing its attack on the Canadian Wheat Board, which the majority of farmers on the Prairies would like to retain as single desk commodity.

Committees of the House April 17th, 2008

Mr. Speaker, the hon. member's question is a timely one. He will remember that in the all party report we did on food security all the recommendations were unanimous, except for our opposition to the way the government was handling the Wheat Board question. All of us agreed that food security is a major issue.

As for the response, I will give an example. One of our recommendations was that all federal government institutions favour Canadian producers, so that for folks in prisons or other federal institutions, and here in the House of Commons, we will ensure that we have good Canadian food. The response from the minister and the department was that we have to be careful of our trade obligations.

I believe it was one of the pork producers from Quebec who appeared in front of our committee and asked us to help them fight the foreign governments. They asked if somebody could help them fight what foreign governments are doing to them.

We need to have a government that stands up for our food security and for our farmers, even at the expense of ruffling a few feathers. I read an article about an attorney from the United States who said that she could not understand why our minister and our department were being so nice to our trading partners. The United States does not do that and we should not be doing it here.

Committees of the House April 17th, 2008

Mr. Speaker, I would like to thank the hon. member for Malpeque for bringing this topic forward for discussion today. I also want to thank my Bloc colleague on the agriculture committee for his eloquent speech a few minutes ago.

Three samples of frozen pork were brought to the agriculture committee today by the hon. member for Malpeque where we were discussing the product of Canada labelling. The member had randomly bought the pork samples at a supermarket here in the Ottawa area. Two of the samples had a product of U.S. label and one had no label on it.

That triggered in me a thought. Here in Canada we have a crisis in the pork industry and animals are being slaughtered, not for consumption but because there are too many of them, and yet at a supermarket, randomly selected by a member of this House, produce can be found that came from the United States. We are not sure where the third sample came from but it was probably from the United States.

Canada has a trade agreement with the United States that allows for the free flow of goods across the border. I suppose, when times are favourable, when our dollar is not that strong and when other conditions are favourable, that is a good idea. However, it seems kind of ironic that we would allow continuing access to products from another country when our own producers are suffering.

Some of the protection measures used by the United States were discussed this morning. It seems to me that when their producers are in a crisis, the American government does not hesitate to assist and ensure help goes to the producers when they are in a crisis. In its farm bill, money has been set aside not only for agricultural producers but for food programs and the environment. The U.S. seems to be able to do that, but here, even with all our good intentions, we always seem to be reacting to certain crises. Now we have a crisis on which we need to react.

I would like to review the recommendations our committee made last December. The first recommendation was this:

The Standing Committee on Agriculture and Agri-Food recommends that Agriculture and Agri-Food Canada deploy, before the end of 2007, a special transitional measure that will provide cash-flow in the form of interest-free loans to be paid back over a period of three to five years, and bankable cash advances to hog and cattle producers.

The second recommendation was this:

The Standing Committee on Agriculture and Agri-Food recommends that Agriculture and Agri-Food Canada, in partnership with the provinces and territories, pay out the remaining percentage owed to producers under the CAIS Inventory Transition Initiative (CITI), and respect the federal-provincial funding agreement.

I will also read the third recommendation.

The Standing Committee on Agriculture and Agri-Food recommends that Agriculture and Agri-Food Canada (AAFC) hold formal discussions with the Minister of Finance to show the impact of the strengthening Canadian dollar on the food producing and processing industry in Canada and to examine ways to relieve the pressure on the industry from the rising Canadian dollar. AAFC officials should report back to the Committee on the result of these discussions.

There were also other recommendations.

The sad thing is that we held our committee meetings, we had our discussions, and we made recommendations, but we had to have another committee meeting to talk about the problems in the pork industry.

Then, as someone already mentioned, there was some activity on the minister's end of things. He consulted my colleagues and me, and then we tried to set something up to help producers, mostly through loans. I congratulate him on that.

However, pork producers are facing impending disaster as we speak.

The government, as have other governments, has attempted to address the situation. When a crisis happens, we do not seem to have anything in place to deal with it. We are always reacting. We need to have a hard look at how we deal with agriculture in our country. Are we going in the right direction?

These days we are talking about the whole idea of food security and food sovereignty. We know many issues can be addressed and should be looked at, as more and more Canadians realize it is important that we are able to feed ourselves as a country, as world feedstocks go down, and as there is a push for the biofuels industry. People are finally realizing the movement across the country for the need to put more emphasis on buying local. I do not think we will get any disagreement from anybody in the House about that issue.

As I mentioned, we are now debating the issue of the product of Canada. I think there is agreement that we have to look at this and improve what we designate a product of Canada so we do not have processors, and the example was used this morning, importing apples from different countries, making them into concentrated juice and then labelling that carton of juice as “product of Canada”. There is something not quite right about that.

When we talk about labelling, in my opinion, labelling a product of Canada should be compulsory. It should not be left up to industry. After 2004, we asked the industry to voluntarily label GM foods, but this has not happened.

As we move on, a number of issues have to be addressed in the area of food sovereignty. Next week, for example, I will be in the small community in my riding of Princeton with a group of people who work on the issue of food security in their community. We will show a film called, TABLELAND, and have a discussion on what this means to that community.

When we get back on April 30, there is going to be an evening in Ottawa, where people will be coming together to talk about the wrong direction the world is going in regard to biofuels and the fallacy of that whole argument.

If we look at Canada's food sovereignty and security and, for example, if we look at the question of peak oil, the industrial agricultural model in Canada was built on, and is heavily dependent on it, our low dollar, as well as the abundant and cheap energy for transportation to market, fertilizer and chemical inputs. These conditions no longer exist and are likely to get worse, making this system unsustainable.

What we are now facing in the pork industry is partly as a result of this. The fact is input costs have gone up, the dollar is low and we have had this free market model to produce with free trade, moving it back and forth as much as possible. Yet the European Union has a quota of 0.5%. Over that, our producers have to pay a tariff to get into that market. At the same, as an aside, at the World Trade negotiations we are being pushed to increase the quota so we can allow more products imported into our country.

Clearly something is not right in the direction we are going. It is time for all of us to look at the idea of our food sovereignty, food security and safety, as we address the crisises that keep come up. Hopefully we can have a plan in place to avert this when they come up. The strong dollar makes our exports too expensive for others to buy. More purchasing power to import food makes us dependent on others for our food supply.

The whole issue of climate change, which we are all aware of and on which we all agree, is increasing drought conditions. We have refugees and resource wars because of this. We have rising commodity prices, which are disproportionately affecting the poor. On top of this, we have the biofuel industry in North America and in other parts of the world, which is not the main reason but one of the reasons that prices of food commodities are going up.

As an example, in the United States farmers are taking away land from soybean production and increasing the land on which they are cultivating corn for biofuels. This means that the effect in Brazil is farmers are planting more soybeans to keep the quota in the world, displacing cattle ranchers from their land to get more land for soybean production. The cattle ranchers are moving into the rain forests and cutting down the forests so they can have land for cattle grazing.

We are getting this spin off effect happening. This in turn is displacing poor people who have been subsistence farmers, in Brazil for example, into the cities. We then have the whole effect of urbanization and migration into the cities.

We see the effect with the NAFTA among Mexico, Canada and the United States. As of January of this year, there has been a free flow of corn across the border. Mexican farmers are not able to compete. They are going broke, so they are leaving their farms, going to the bigger cities and migrating to the United States to work for menial jobs, probably on the black market somewhere, to make a living.

It is time now that we look at the whole industrial model of agriculture. It is time we look at a way of having sustainable communities.

I was in Saskatchewan a few weeks ago and met with some folks who were concerned about the state of agriculture in their province and in Canada. They are saying that they need a policy that looks at not only how they can make the farm more efficient and larger to compete, regardless of our dollar, and keep it moving in that direction. They also need a policy that looks at each community and how they can attract people into the community who can farm, who can have a farm on the outskirts of a small community, for example like Blaine Lake, where my family members grew up.

As well, we need to not only have that community there for farmers, but we need to have affordable housing and a community that is sustainable and able, within the parameters of the community, to feed itself and also feed people in that province and in Canada.

As we move on and look at the way the whole agricultural industrial model is developing, I predict that we will see, and we see it now, more people moving back to rural Canada and who want to work on sustainable farms.

In my area of the West Kootenays, we have an area just across the mountains, called the Creston Valley, wherein folks are now going to start growing wheat again because there is a demand for it in cities like Nelson and in the West Kootenays, keeping in mind the whole idea of food sovereignty and the 100 mile diet. We see this as a model.

I had mentioned also the whole area of biofuel production. I have many concerns in regard to the current legislation before us. I regret that the amendments I had for Bill C-33 in committee were not passed.

I will read the amendments because I think that had they been passed by our committee and approved by Parliament, we could have more of a sustainable direction in the area of biofuel production.

The first amendment rejected was:

—prohibiting the use of genetically modified grains, oilseeds or trees for biofuel production, except for those genetically modified grains, oilseeds or trees that were used for biofuel production in Canada before 2008...

In other words, what I wanted to have put in with this amendment was that we are not going to give a green light to genetically modified wheat, which in turn would have that contamination effect, would lower the quality and would lower our prestige in the world.

The second amendment I wanted to have put in was:

--prohibiting the use of lands protected by federal legislation and other sensitive biodiverse lands for biofuel production;...

The third one rejected was:

--preserving the biodiversity of lands used in biofuel production;...

The fourth one rejected was:

--prohibiting the importation of grains or oils for use in biofuel production;...

Last week, an editorial in the Manitoba Co-operator stated that Husky Oil in Lloydminster, Saskatchewan, and in Minnedosa, initially was going to rely upon locally grown wheat, second quality wheat, which fits in with the Manitoba government's policy of 10% of land devoted to biofuels. However, because of the prices in the grain industry, farmers are not taking the company up on this. The article said that the company is going to be using corn exclusively, because it is complicated to go back and forth between wheat and corn for ethanol production.

The corn now is grown in eastern Canada, of course, but there is also a biofuel industry initiative in eastern Canada. The fact is that the corn now will have to be imported into Manitoba to sustain Husky Oil. Our farmers really will not be taking part in this industry initiative unless they happen to work at that plant.

The other amendment I wanted to put in was this one: establishing criteria in relation to the environmental sustainability of biofuel production to ensure compliance with internationally recognized best practices that promote the biodiversity and sustainability of land, air and water, and also to establish restrictions on the use of arable land in Canada for biofuel production to ensure that biofuel production does not have a detrimental impact on food supply in Canada and in foreign countries.

Now we come to the argument about food for fuel. I think it is a very logical statement that there is land in the world today that is being taken out of food production to sustain a biofuels industry. Recent research, not only here in North America but in the world, shows that taken in a general context biofuel production does nothing to reduce greenhouse gas emissions. By the time we have taken the input energy, the transportation energy and the energy to power the biofuel plants, it becomes unsustainable when we look at it from the point of view of the environment.

I am not sure if members are aware of this, but the hon. member for Malpeque and others of us on the committee went to Washington. We were told by the Americans that they are pushing the biofuels industry in the United States because they have a cap on their imports. They are pushing it because they need more fuel to “fuel” that rising demand. That will come from biofuels produced in their country at the expense of farming.

In summary, I think now is the time for us to take another look at this and to have a new direction in the area of agriculture. I believe that the whole issue of food sovereignty and food security tied in with sustainable farming communities is the direction we should be taking.

Forestry Industry April 11th, 2008

Mr. Speaker, last week Kamloops lost 200 jobs when the Weyerhaeuser sawmill closed. Last summer close to 200 jobs were lost when Pope & Talbot closed in Midway. Working families are suffering in the Kootenay Boundary and in Kamloops. Families in Kaslo are also hurting due to the Meadow Creek closure. They still do not know if they qualify for the $1 billion fund.

Can the minister tell the House if the workers from Kamloops, Midway and Kaslo qualify, yes or no? If so, when will he release the funding?

Questions Passed as Orders for Returns April 9th, 2008

With respect to Canadian Agricultural Income Stabilization (CAIS) program entitlement, the appeals process and exclusion from entitlement to other federal agricultural programs: (a) are appellants entitled to know what recommendations are made by the Western Amalgamated Appeals Sub-Committee and, if so, how is a copy of the recommendations obtained by the appellant; (b) are appellants entitled to know on what grounds the Intermediate Appeals Sub-Committee rejects recommendations of the Western Amalgamated Appeals Sub-Committee and, if so, how is a copy of the recommendations obtained by the appellant; (c) has the CAIS administration ever issued rejection letters to an appellant before or after soliciting the involvement of an appeals committee and, if so, how is a copy of the motion or other directive permitting this obtained by the appellant; (d) who is responsible for forwarding recommendations made by the Western Amalgamated Appeals Sub-Committee to the next level of appeal; (e) are there any legitimate grounds upon which the National CAIS Committee (NCC) administration is allowed to refuse an appellant the full extent of an appeal by neglecting to forward the recommendations of the Western Amalgamated Appeals Sub-Committee to the next level of appeal; (f) does the appeal process deal with appeals on a case by case basis or can the NCC administration short-circuit the appeals process based on a judgment that an appellant's complaint is just like the one that may have preceded it; (g) are there guidelines established that would give an appellant a reasonable expectation of the time it should take to address an appeal at all the various levels and, if so, what are the guidelines that govern a reasonable expectation; (h) is the appellant justified in expecting that the decisions made by appeals committees will be communicated to the appellant; (i) what are the circumstances under which it would be acceptable not to inform the appellant of decisions made by appeal committees; (j) is it a reasonable expectation on the part of the appellant to expect that the decision of their appeal would not be discussed by the NCC administration, to the public or a competitor without the approval of the appellant and, if so, what recourse is open to the appellant if this expectation has not been respected; (k) would the public circulation of a decision made by the NCC administration without the appellant's express permission constitute a “moral hazard” for the purposes of the Principles of the Transition Agreements, section 14.1.3; (l) would such an action call into question the integrity of the appeals process and compromise the quality and legitimacy of the decisions and decision making process, as they applied to the appellant; (m) how many times is it acceptable to change the reasons that are given to a producer for their exclusion from a program; (n) when a historically precedent-setting change to the eligibility criteria of producers to Business Risk Management (BRM) programs are made, who bears the responsibility of ensuring that these changes in direction are clearly and adequately communicated to the agents of the program and who bears the responsibility to articulate these precedent-setting changes in the guidelines; (o) is the producer under any obligation to demand of the purchaser an accounting or history of the purchaser's previous use of the product in order that the producer may be eligible for BRM and, if so, what is the justification for this under the CAIS program; (p) if the purchaser’s intended end use of the product changes after the purchase has been made, is the producer then entitled to re-apply, if they have previously been denied program funding because of the purchaser’s stated intended end use of the product; (q) what level of appeal hears issues that may pertain to situations where the guidelines are in conflict with other over-riding legislation or previous implementation agreements and does this level have any authority to bring resolution to a conflict;

(r) what is the duty of the NCC administration to ensure that they are correctly following their legislative duty to Parliament to act in accordance with the legislation; (s) are the administrators of the CAIS program accountable to the government if they fail to act in accordance with the legislation and statutes; (t) what avenues are open to the appellant once the appeal process comes to an end, if they can show that the legislation and duly signed implementation agreements have not been followed; (u) are there any circumstances under which the NCC is allowed to approve the implementation of guidelines that are inconsistent with legislation and, if so, where in the legislation is that entitlement articulated; and (v) what avenues are open to the appellant to prevent the NCC administration from moving a matter to Revenue Canada for collection, once all avenues under the appeals process have failed, when there are conflicts between legislation and program guidelines?