An overview of producer group submissions to the Canada Grain Act review

The deadline for submissions to the Grain Act review consultations is coming up on April 30, 2021.

In anticipation, producer and policy groups from across Canada are urging farmers and industry players to submit their thoughts on changes and improvements they’d like to see in the act going forward.

Farm groups have also outlined the main areas of focus in the submissions already submitted on members’ behalf.

Here’s a snapshot of how that breaks down (alphabetically, by group):

Agricultural Producers Association of Saskatchewan

• Strongly supports the continued mandate of the Canada Grain Act and CGC to protect the interests of producers in Canada’s grain industry
• Supports the continuation of the three Commissioner governance structure in the Canada Grain Act.
• Supports the continuation of mandatory CGC outward inspection in the updated Canada Grain Act. It is important for decision makers to recognize that primary producers face the greatest financial risks when there are perceived quality concerns in international markets
• Calls for greater transparency and timely information about export shipments and sales commitments. The Canada Grain Act review is a critical opportunity to ensure enhanced information sharing about export sales
• Is calling for appropriate levels of federal funding for the CGC. The user fee funding model results in a lack of sustainable federal funding for CGC services and programs
• The CGC should take steps to exercise more inspection authority over testing procedures and accelerate the modernization of the grading system to improve quality assessment.

Alberta Wheat & Barley Commissions

• Eliminate the provision of mandatory services by the CGC, including outward weighing and inspection of outgoing grain vessels. The CGC would instead accredit third parties to test and inspect grain exports on a competitive basis in line with customer demand. Approximately 80 per cent of export shipments are currently double inspected due to the requirement for a CGC inspection, plus contractual obligations for a third-party inspection. These additional costs are passed onto farmers through lower grain prices.
• The direct costs of regulation by the CGC must no longer be hidden in the grain basis, and should be shown as a fee on producers’ grain sales for increased transparency. The fee calculation should be adjusted annually to maximize the use of surplus funds from the previous year.
  CGC functions provided for the good of all Canadians such as the Grain Research Laboratory must be fully funded by Canadian taxpayers.
• The CGC must expand their role in regulating and enforcing grading methods and procedures for domestic transactions of grain wherever CGC standards are used for quality assessment.
• The producers’ right to dispute grading results, subject to the CGC inspector’s assessment must be expanded to include assessment of non-grade requirements (i.e. Falling Number and DON), and the right to dispute grading results must be available to a producer for a window of five business days from the date of a grain delivery.Other recommendations include empowering the CGC to provide more timely dissemination of information on grain exports.

National Farmers Union

• Keep the CGC mandate: “the Commission shall, in the interests of the grain producers, establish and maintain standards of quality for Canadian grain and regulate grain handling in Canada, to ensure a dependable commodity for domestic and export markets.”
• Maintain the CGC governance structure headed by three Commissioners, and reinstate the Assistant Commissioner role.
• Repeal all Bill C-4 amendments to the CGA not required to implement CUSMA, including clauses enabling the CGC to assign Canadian grades and dockage to wheat imported from countries other than the USA.
• Secure CGC’s full authority over grades, classes of grain and variety designation.
• Retain the bond security system for producer payment protection and enable more frequent mandatory reporting.
• Maintain mandatory CGC outward inspection, reinstate mandatory incremental loading, and require certificate final be provided to the export customer as well as to the shipper
• Re-establish mandatory CGC inward inspection
• Implement mandatory daily grain sale price reporting with reported prices available online and posted at country elevators
• Expand access to binding CGC determination to include all licensees, and all specifications included in farmers contracts, with no fee charged for binding determination; contracts must be prohibited from implying any other assessment supersede the CGC’s determination
• Require grain cash ticket to include and itemize freight, elevation costs, and all other deductions
• Add a class of license to cover container shipper loading facilities other than producer car loading facilities
• End the exemption from licensing for commercial feed mills other than co-operative feed mills owned and operated by the farmers who deliver to the mill
• Establish and operate a CGC Producer Car Receiver to receive producer cars at the West Coast and Thunder Bay to ensure producer cars remain an effective element in the grain handling system
• Ensure the CGC’s research capacity and scope is fully supported as a core regulatory function
• Explore the possibility of extending the CGC’s authority to cover Eastern Canada

Saskatchewan Wheat Development Commission

• Calls on the Canadian Grain Commission (CGC) to create an export sales reporting program to put farmers on equal footing with other supply chain participants and enable farmers to make more informed marketing decisions
• Sask Wheat believes that it is vital that the CGC’s mandate continues to be to work “in the interests of the grain producers,” that the CGA and Canada Grain Regulations are applied according to this mandate, and that the functions, activities, and initiatives of the CGC reflect this mandate at all times
• As part of protecting the Canadian brand, Sask Wheat is in favour of mandatory outward inspection remaining as a function performed by the CGC
• Sask Wheat believes that any determined uses of the accumulated surplus need to go towards activities that will directly benefit farmers as they are the primary source of CGC fee recovery, despite licensees collecting and remitting fees to the CGC
• To ensure farmers have access and coverage under the CGC’s producer protection services, Sask Wheat is requesting that licensing requirements be extended to include feed mills and container-loading facilities.
• In regards to Subject to Inspector’s Grade and Dockage (STIGD), Sask Wheat is requesting that the CGC define a specific window for how long a grain company must hold onto a farmer’s grain sample that will allow farmers to challenge an elevator’s grade after delivery, within that window. Adding non-grade determinants, such as DON and Falling Number (FN), to the STIGD process would also strengthen this tool for farmers
• Sask Wheat also has significant comments regarding Producer Payment Protection and CGC Oversight on objective measurements

Western Canadian Wheat Growers Association

• Outward weighing and inspection should be performed by 3rd parties
• Governance model should better represent jurisdictions with CEO and board of director structure
• Funding should involve a combination of public and private funds
• Surplus should be returned to the farmers who funded it
• Grading should allow flexibility to better reflect the buyers needs

The Keystone Agriculture Producers plan to release details of its submission on Friday, April 30.

To include your say in the review, please visit this site.