APAS’s Submission to the

Canada Grain Act review

In April, the Agricultural Producers Association of Saskatchewan provided its submission to the Government of Canada's consultation on the Canada Grain Act. Our submission was based on years of discussion by our reps and policy committees. The submission stresses the importance of maintaining a producer-focused mandate and governance structure for the Canadian Grain Commission (CGC) in the Canada Grain Act. We also called for outward inspection to remain a function of the CGC. Our submission also joins with other producer groups in calling for greater transparency in market information like export sales figures so that producers have better information on market demands. Other important APAS priorities include improving quality assessment processes under the CGC's authority and the need for increased funding from the Federal Government for the Commission. Here is a summary of APAS's submission to the Canada Grain Act review.

Legislative Framework

Recommendation 1.1 APAS requests that any updates to the legislation must maintain the CGC’s core mandate to work in the interest of producers. This mandate must furthermore direct this review process and its outcomes. Recommendation 1.2: APAS supports the continuation of the three-Commissioner governance structure in the Canada Grain Act to ensure producer representation at the Commissioner level. Recommendation 1.3: APAS requests increased federal funding for CGC programs to fully support public good services that benefit all Canadian and to reduce the reliance on user-fees to cover operational costs.

Commercial Services and Protections

Recommendation 2.4: APAS recommends that the CGC conduct a separate and focussed review of potential changes to payment protection programming with focus on improving program transparency and examining the development of more flexible security options to accommodate the needs of new entrants and classes of licensees.

Recommendation 2.5: APAS requests that the CGC resume its licensing review to address gaps in oversight and producer protection, which could include further discussions with affected stakeholders about modifying administrative and security requirements specific to the purposes of licensing.

Export Programs

Recommendation 3.1: APAS supports the continuation of CGC outward inspection in the Canada Grain Act, while ensuring that cost considerations are addressed through a CGC funding model that receives the appropriate level of federal investment in programs that benefit all Canadians. Recommendation 3.2: APAS recommends that the CGC enhance its reporting requirements for export sales and shipments to develop a statistical reporting program modelled on the USDA Export Sales Reporting Program.

Other Issues

Recommendation 4.1: APAS continues to support the CGC’s Grain Grading Modernization Initiative with a focus on reforms to reduce reliance on subjective and visual methods of assessing grain quality. The CGC should look to accelerate this initiative where possible and encourage greater producer engagement through a regular reporting of status updates and next steps. Recommendation 4.2: APAS strongly supports the continuation of legislative provisions concerning access to producer cars in the updated Canada Grain Act. Producer car protections should be strengthened through the use of legislative provisions to provide competitive access to port handling and loading services.

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