Submissions

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.

CFA submitted its comments on the proposed new National Potato Wart Response Plan.

At a high-level, CFA recommended the following:
– CFIA requires adequate funding and human resources for implementation of the plan.
– CFA supports increased funding and research into resistant potato varieties.
– Update the CFIA compensation regulations, as they have not been revised since 2003. It should address the loss of future potato revenue and the devaluation of land.

Considering the increasing incidence of extreme weather and other disaster or emergency events which are costing the agriculture sector and the Canadian economy billions every year, the CFA understands the need for, and is generally supportive of, Canada’s Emergency Management Framework for Agriculture in Canada.

However, we offer the following specific comments on the Framework, for consideration as the Department of Agriculture and Agri Food Canada (AAFC) gathers insights on ways to improve the Framework:

– Clarify roles and responsibilities
– Increase capacity building
– Enhance visibility, understanding and communication of the framework
– Incorporation of new emerging threats
– Incorporation of Lessons Learned from COVID-19
– More structured post-emergency analysis
– Better alignment of Business Risk Management (BRM) programs as part of response and recovery activities
– Ensure that commodity / sector-specific emergency management traceability programs are recognized