Submissions

The recent surge in gopher populations—driven by prolonged drought and consecutive years of unchecked spread—is causing significant economic losses, environmental degradation, and operational disruptions for producers. In some Prairie regions, gopher infestations have led to significant reductions in crop, hay, and pasture yield. Their extensive burrowing damages irrigation systems, undermines soil structure, and interferes with farm machinery operation and causes expensive machinery damage, while also reducing available pastureland and other feed sources for livestock in times of drought and causing potential injury to livestock. The 2024 ban on strychnine has further limited effective control options, exacerbating the problem for many producers. Strychnine remains the most effective option available for managing gopher populations and other burrowing rodents that pose serious threats to crops, infrastructure, and farm productivity.

We understand the Pest Management Regulatory Agency’s 2024 decision to cancel all uses of strychnine due to environmental concerns, particularly risks to non-target wildlife. To help mitigate the concerns associated with the use of strychnine, we support the implementation of strict control measures, handling guidelines, and comprehensive monitoring and reporting to mitigate environmental risks.

We also urge Agriculture and Agri-Food Canada to prioritize and invest in the research and development of alternative pest control solutions that are both effective and economically feasible.

On August 1st, CFA made its submission to the ongoing Federal pre-budget consultations.

At a high-level, the submissions recommended to:

– Align regulatory frameworks with a growth-oriented agenda—by mandating key regulators to explicitly support Canada’s food security and competitiveness objectives.
– Provide a blanket remission for all currently impacted and future potential critical farm inputs subject to the Government of Canada’s Countermeasures in Response to U.S. Tariffs on Canadian Goods.
– Ensure that the new $5-billion Trade Diversification Corridor Fund prioritizes the needs of the agriculture and agri-food sector.
– Permanently increase the interest free portion of the Advance Payments Program to $350,000 and streamline administration requirements.
– Ensure the agricultural streams of the Temporary Foreign Worker Program (TFWP) are maintained to support farmers’ seasonal and temporary needs.
– Immediately launch consultations with industry representatives and implicated stakeholders to explore options to address the root causes of labour disruptions.
– Introduce a permanent Accelerated Capital Cost Allowance across all classes of farm equipment that would allow producers to depreciate 100% of their capital allocated to purchases of farm equipment.
– Commit to modernizing the Canada Grain Act (CGA) in consultation with producers.

As part of the Flip the Switch campaign, CFA signed on to a letter sent to the Minister of Transport and Internal Trade.

In the letter, it noted the commitment withing the Liberal platform to renew the extended railway interswitching pilot by three years, and urged them to prioritize following through on this promise.

The letter also noted that we hope to see a path to permanency, with an increased radial distance of 500km that also includes British Columbia.

We are asking for the removal Canola from the retaliatory tariff list that is currently in effect. Together, with the tariffs placed on Canadian canola meal and oil by China and other challenges currently facing the industry, these self-imposed Canadian tariffs on canola seed from the U.S. will only further harm and punish the Canadian agriculture sector, starting at the farm gate, at a time when we can least afford it.

CFA signed onto a joint letter to the FPT Ministers of Agriculture and Fisheries that outlined how to harness and grow the potential of the Canadian aquaculture sector. The letter outlined the following recommendations:

– Science must be at the foundation of aquaculture developement
– The BC “Open Net Pen” ban must be removed
– Agriculture and Agri-Food Canada must be the Federal aquaculture champion
– Shellfish sector management and risk supports must be modernized

CFA submitted its comments the proposed Federal Offset Protocols for reducing manure methane emissions.

In the comments CFA noted some concerns with the protocols, including:

– The criteria for “baseline conditions” exclude existing livestock operations that are already implementing good manure management practices. These criteria exclude and penalize early adopters of such technologies. The protocol should be adapted so that farmers already managing manure are immediately eligible.
– The legal additionality clause of the proposed protocol, which disqualifies GHG reductions from earning credits once they become legally required. Given the complex and variable nature of manure management regulations across provinces and municipalities, the CFA recommends a buffer period be added to allow continued crediting for existing projects, ensuring farmers can recoup their investments.
– The that prevents changes to a project’s geographic boundary after the first reporting period. The CFA recommends allowing some flexibility to accommodate situations like new farms joining an aggregated project or farm acquisitions, which would support broader technology adoption and reduce administrative burdens for future participants.
– There is a need for more clarity and better alignment among the different offset systems and carbon credit markets in Canada.
– The absence of an explicit economic lens in the protocol.

The Canadian Federation of Agriculture (CFA) has contributed to biodiversity conservation through policy work and stakeholder engagement. Key initiatives include the Canadian Agri-Food Sustainability Initiative (CASI), which developed an online platform for sustainability programming, and participation in the government’s Sustainable Agriculture Strategy (SAS) advisory committee. CFA is also involved in the Canadian Wetlands Roundtable, promoting wetland conservation and sustainable management practices. Challenges include fragmented data, unclear biodiversity standards, and the need for financial incentives for farmers. Future efforts will focus on soil health, ecosystem valuation, data strategy, and advocating for farmer inclusion in biodiversity policymaking.

The Canadian Federation of Agriculture (CFA) made a submission to the Canadian Grain Commission on the proposal to replace the current Grain Standards Advisory Committees with a Grain Standards Advisory Forum model. While the CFA is supportive for efforts to strengthen grain grading and quality, including steps to ensure the engagement is more inclusive of all grain sector stakeholders, the CFA is of the view that greater clarity on the assessment of the challenges, gaps and issues with the current CGC Grain Standards Advisory Committees is needed before committing to further reform.

To strengthen Canadian competitiveness, we strongly urge the incoming government to take the following action:

– Unlock private sector investments through competitive tax policies that level the playing field with other jurisdictions, particularly the U.S., such as accelerated depreciation or investment tax credits on infrastructure and supply chain investments.
– Reform regulatory processes for the approval of infrastructure and major resource projects so that decisions are made quickly, with timing predictability clear from the outset, while allowing for adequate public consultation.
– Modernize Canada’s labour laws to mitigate economic harm and improve supply chain reliability by establishing a clear and transparent process to resolve
disputes rapidly in the transportation sector.

The CFA supports the goal of providing Canadians with measures that prevent misleading labelling practices, including “greenwashing”, that empower Canadians to make informed decisions.

However, the CFA continues to express concerns regarding the greenwashing provisions, the proposed guidelines, and the extension of the private right to action to environmental claims. These concerns are exacerbated by the current political and economic uncertainty currently facing Canada.

As detailed in CFA’s previous submission, the newly added provisions are vague and undefined, especially terms such as “internationally recognized methodologies”. Furthermore, the CFA is concerned with the potential increase in frivolous lawsuits due to the expansion of the private right to action that would push businesses to remain silent and thus contribute to “greenhushing” instead of effectively combatting “greenwashing”.

CFA submitted a letter to the Ministers of Finance and National Revenue to express concerns with the decision to administer the proposed capital gains inclusion rate legislation without parliamentary approval.

CFA recommended that the CRA does not move forward with these changes unless they receive parliamentary approval, as these changes would have negative impacts on farm succession.

The submission expressed concerns with the potential implications of any proposed measures to impose a tax on residentially zoned vacant land.

Specifically, CFA’s main concern with the proposed new tax measure is the potential for agricultural lands to be misclassified, leading to unintended taxation and additional financial strain on farmers, as many agricultural lands may appear vacant due to crop rotations or the need to leave the field fallow.

As a result, the CFA recommended that the Government of Canada consider an explicit exemption for land that is in use for agricultural purposes, regardless of the zoning classification.