NFU Submission on Red Tape

This was submitted to the Manitoba Government by request as part of their initiatives to reduce “Red Tape”.

Thank you to Manitoba Premier Brain Pallister and Minister of Agricultural Ralph Eichler for this opportunity to provide suggestions on how to reduce Red Tape for Manitoba farm families.

The National Farmer’s Union – Region 5 (Manitoba) (NFU-MB) fills an important role in Manitoba’s agriculture sector. Other organizations promote specific commodities, or general production. The NFU – Manitoba is a general farm policy organization which promotes and supports the interests of Manitoba farm families who are the drivers of agriculture in Manitoba.

Our Manitoba farm families appreciate efforts to reduce the red tape which affects their farm income and workload but caution that adequate consideration be given to changes to ensure that families are not harmed by red tape reduction.

In reducing any red tape, we must first consider why it exists and ensure that changes do not create new problems. The term “Red Tape” is said to originate from the use of ‘red tape’ to bind up final legal documents or decrees, written laws, or contracts. These documents are necessary to conclude agreed upon actions or guide actions of conduct among people or by government or by business. “Red Tape” therefore, refers to the documents and actions and decisions previously discussed and agreed to by Manitobans. Each existing government (or private business) related “red tape” rule or regulation was at some time or other extensively negotiated between two or more agreeable parties, or was imposed upon society and business for a real purpose by a government vote. In Canada’s case this is Democracy in action.

A very ancient rule, which fits under the definition of “Red Tape” is that traffic shall pass on the right side-in our part of the world. Although inconvenient in a few isolated situations, this rule and the red tape it creates is clearly accepted as a benefit for civility and the completion of business.

If there is an accumulation of out of date documents, rules or regulations which appear to impede the flow of public or private business or services, this could now be said to be unnecessary “Red Tape”. In Agriculture, careful debate, context, real data, and consideration of the impacts on farm families are needed when changing those decisions made in the past and now considered unnecessary “Red Tape”. Successful regulations take a wide variety of interests into account and serve a greater good.

NFU-MB continues to press for a properly regulated and civilized agriculture with rules which level the playing field and ensure that all farm families have equal opportunity. We lobby against monopolization and collusion, against attempts to ignore effects to public health, against attempts to ignore environmental costs and against attempts to skew the rules in favour of a powerful few. Governments must be careful with Red Tape and be fair, remembering to level the playing field and to avoid picking winners at the expense of the greater good like the environment, clean water, the lower class or by allowing the market to run so freely that it inevitably leads to major barriers to entry thus leading to monopolization.

NFU-Manitoba requests your consideration of the following issues:

1. Reducing Red Tape in Farm Representation: Thank you for considering that every farm and farm family is unique and that Manitoba Farm Families are best positioned to choose which farm organizations best represent them. The NFU-MB asks that you remove the red tape which restricts farmer choice of voice by changing the Manitoba Agricultural Producer Organization Funding Act Part 3, Division 1, 16 (2) to allow several complementary General Farm Organizations to be funded. This choice of voice will reduce red tape while allowing your government to be more in tune with the needs of today’s diverse farm families and thus strengthen your success in making sound decisions in Agriculture.

This change has been made in other Canadian provinces and the effect has been positive toward their rural populations. Ontario has had this choice in place since 1995 and has concluded that more farmer participation has occurred, better farmer information is forth coming to the government, and better decisions are made in respect of farming matters as a result.

The NFU in Manitoba is prepared to assist the Manitoba Government in building a made-in-Manitoba General Farm Organization funding model. This will reduce red tape for Manitoba’s farm organizations, for Manitoba’s government, and for the buyers of farm commodities, while allowing the Manitoba Government to develop stronger agriculture policy.

This change has been made in other Canadian provinces and the effect has been positive toward their rural populations. Ontario has had this choice of voice in place since 1995 and has concluded that more farmer participation has occurred, better farmer information is forth coming to the government, and better decisions are made in respect of farming matters as a result.

2. Reducing Red Tape in Poultry Production: Thank you for recognizing that summer pastured poultry is a unique product, distinct from supply managed poultry. The NFU-Manitoba requests that red tape be reduced by officially recognizing all summer pastured poultry as a distinct quality and class of poultry, as allowed in the Manitoba Farm Products Marketing Act, Part 2.3 (1) (g), and that summer pastured poultry so become removed from the jurisdiction of supply management associations including the Manitoba Chicken Producers and the Manitoba Turkey Producers. Current regulations make the false assumption that the consumers who buy pastured poultry would switch to commercial poultry. This is absurd. The complicated and unworkable system for tracking pastured poultry within the supply management system does not work and should be abandoned by recognizing pastured poultry as a distinct product serving a distinct market.

3. Reducing Red Tape in Taxation: Thank you for recognizing that farm families need services, such as Education, Health Care, Roads, and Hydro. NFU-MB is in favour of fairly levied taxation which uses tax dollars wisely, provides services and makes farming viable for more farmers. We are particularly concerned that young, new farmers are being shut out of the business due to their inability to compete against established farms. Most young farmers start small with a high debt load. While no one likes to pay taxes, the removal of the school tax rebate cap will be a direct harm to young, new farmers. Most large, established farms are in a growth cycle which demands annual land purchases to service their debt. By gifting these large established farms with the school tax rebate your government will simply release funds for land purchase, which will continue to drive land prices up and farther away from the reach of young, new farmers. In this case, moving the rebate cap of $5000 higher could help new and young grain farmers but completely removing the education land tax would have real consequences on the price of land. Please think carefully about the long term effects of rebate cap removal.

4. Reducing Red Tape in Farm Labour: Thank you for recognizing that the Seasonal Agricultural Workers Program creates red tape while producing a two tiered labour force in Manitoba. The NFU-MB requests that red tape be reduced by considering seasonal farm workers as equivalent to immigrants, thus supporting the majority of Manitoba’s farm families which do their own labour or use Canadian workers. Many farms take time training these employees and so the option to give them long term work should be available.

5. Reducing Red Tape in Food Safety: Thank you for recognizing the booming economic opportunity of direct farm marketing in which consumers buy food direct from the farmer which produced it. This direct connection produces superior traceability, accountability and the best in food safety. The NFU-MB asks that direct marketing farmer-processors be exempted from red tape such as the HAACP (hazard analysis and critical control points) system which applies to disconnected, untraceable and unaccountable large food processors. We must consider scale specific regulations in this regard that do not tie the hands of well intentioned direct market farmers. A better certification method in food handling for smaller scale farms that allow them to operate with standardized competency in food preparation would make sense.

6. Reducing Red Tape in Crop Research: Thank you for recognizing that the current system of check-offs, which force farmers to pay the full cost of crop research, is inadequate. Food production and trade are public benefits which provide a significant number of jobs to the Manitoba economy. The check-off system forces farmers to subsidize agriculture twice – once through seed royalties and then again through the check-off. The NFU-MB asks for an increase in public funding of seed and crop production research. Our consumers realize they need to help with crop research so their food supply is not challenged by pests or a lack of adaptable crops in future.

7. Reducing Red Tape in Clean Agriculture: The NFU in Manitoba requests that you reconfirm your support for the Government of Manitoba’s existing contract with the NFU-Manitoba for research funding of the Climate Change Action Fund so that all farms can move forward to reduce their Greenhouse Gas emissions. This project will help Manitoba farm families save money and gain social licence by identifying effective emission reduction strategies and best management practices. We anticipate that the Manitoba government will honour your existing contract but have yet to receive the promised funds.

8. Reducing Red Tape in Building Codes: The NFU – Manitoba is concerned that efforts to cheapen the construction of industrial size livestock barns will hurt Manitoba farm families in long run. An Industrial barn with employed labour does not have a strong social licence. Your Manitoba Government has indicated your wish to remove some fire codes from industrial barns. In the event of a barn fire, cheapened construction would endanger hogs, employees, and fire fighters and damage the social licence of other Manitoba farm families. We remind you that due to consolidation, these industrial farm buildings are owned by less than 1% of farm families. Poor building codes for industrial size operations will cause more harm than good. Please consider size and labour when adjusting regulations for barns. Please also consider that building standards and labour standards are important for a strong safe business in industrial agriculture.

9. Reducing Red Tape in Agricultural Business Risk Management Programs: NFU – Manitoba notes that:

AgriInsurance works quite well for Manitoba farm families with a large participation rate. AgriInvest is regarded as somewhat useful if the farm family happens to have left over income to place into this account. The formula should be improved to help farmers to gain a more solid financing.

AgStability is a failed program due to its use of accrual accounting which forces farmers to calculate their income based on a hypothetical value of unsold goods. It is recognized that this program was constructed and might work for the operations which are extremely specialized. However it does not work for any farm family which produces more than one product. On top of this, having the funds engage at a whopping 30% loss makes attaining funds hard to come by. The previous 15% loss engagement made a lot more sense.

Any Red Tape reduction attempts to improve these Business Risk Management programs should address the need to make these programs work for the majority of farm families, to work for diversified operations, and to take multi-year loss from drought or flood or crop disease into account.

10. Land Ownership rules: NFU-Manitoba asks that the rules regarding farm land ownership in Manitoba be strengthened so that Manitoba Residents are the owners and the workers of Farm Land in Manitoba. This ensures that the interest of Manitoba business is maintained and that investment is thus drawn to live and to work and pay tax within Manitoba to support all of Manitoba business and the economy.

11. Water regulations: NFU-Manitoba observes there is a long history of water regulations which involve great debates and best regulations were developed. Concern should always be to balance flood or drought conditions and maintain natural conditions. Wet lands are important to farmers, but have been reduced in area and this is not so good for the Environment or for infrastructure. Government must be there to step in and maintain our wetlands. Excess water is a problem that troubles farmers too often, some insurance measures to aid in regard to excess water troubles would help farmers. Where water is to be used under license, proper Environment Assessment should be done for clean water and for waste water.

12. Reducing Red Tape on Grain Dryer Set-up: NFU-MB asks that the provincial government find a way in which to safely allow for new or used grain dryers to be set-up in a reasonable amount of time. We know of farmers who have had to wait much longer than is reasonable to setup a grain dryer mostly due to the slow process of dealing with gas line regulations. This can have a real impact on business and livelihoods in a wet season.

13. Reducing Red Tape in the Public Funding Time Lag: NFU-MB recognizes that commodity groups match research dollars with government funds. It is important that the provincial government recognize that research generally depends upon doing work in Spring, Summer and Fall for crop trials etc. If funding is not in place by January, it is difficult to plan ahead. We ask that the provincial government keep to a funding schedule when it comes to agriculture research that does not get bogged down by needing approval from several different government committees.

Thank you for considering this submission from the NFU – Manitoba and for working with us to reduce red tape in support of Manitoba’s hard working farm families.

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