Representatives of the Ontario Cattlemen's Association (OCA), the Ontario Sheep Marketing Agency (OSMA) and the Ontario Veal Association (OVA) attended the consultation session held in Guelph on April 15. While in general agreement with the intent of the development of an Agriculture Policy Framework, we offer the following comments and suggestions.
APF
Objective
The APF holds up a very worthy goal: "For Canada to be the world leader
in food safety, innovation and environmentally-responsible production."
The five elements, or pillars, of the APF seem appropriate in the pursuit
of the overall objective. Appropriately, Ministers of Agriculture have pledged
to develop an agriculture policy that is "comprehensive, integrated
and ensures that farmers have the tools to address issues, be competitive
and capture opportunities in the areas of science, food safety and environmental
stewardship." Importantly, the Ministers agreed that certain principles
must be followed including input from industry as well as stable and long-term
funding for each main element of the framework.
Cooperation
and Commitment Needed
The development of an Agriculture Policy Framework represents a fundamental
shift in agriculture policy, one that requires absolute cooperation between
the federal and all provincial governments to be successful. Does the commitment
to the APF truly exist with each government involved? There must be clear
criteria and binding documentation to ensure each government agency remains
committed to the APF over time. For example if one province wishes to have
a higher level of investment or differing criteria, what are the consequences?
To ensure that the APF is developed and understood in the proper context, we suggest that all governments party to the APF, commit to the following policy statements:
1. The Canadian agriculture industry is of critical importance to the health and economic well being of all citizens.
2. All federal and provincial governments fully support and will actively partner with industry toward the orderly growth and enhancement of the agriculture sector.
3. Governments recognize the need for all parties in the agrifood continuum to receive adequate compensation for long term viability.
4. Governments commit to working with industry stakeholders toward an understanding and appreciation of agriculture by Canadians.
These policy statements are critical in the ongoing development and delivery of the APF. They also show a commitment to agriculture that is not now formalized. In fact, they would be seen in a positive, direct contrast to the unwritten, yet oft-referenced, "cheap food" policy.
Branding
The APF holds the allure of "Branding Canadian products". The
key to the success of any brand is its ability to attract a premium in the
marketplace for the features attributable to that brand. The APF falls seriously
short on defining how premiums would be generated. While consumers speak
quite emotionally of the attributes of products for which they are willing
to pay a premium, the reality is often quite different when faced with two
products of differing price. Placing demands on Canadian food producers
with the hope of a premium is, in fact, a high-risk gamble. Meeting many
of society's wishes regarding agriculture production will, inevitably, increase
cost of production. There simply must, in these cases, be a premium associated
with that production practice. The agriculture sector cannot afford any
more gambles than it already faces through the unpredictability of weather
and global marketplaces.
Cost/Benefit
Analysis
Regardless of how far or how fast the various aspects of the APF move forward,
a critical element in its development will be the analysis of the cost/benefit
of each component. For example, in the APF presentation and background material,
tracing of livestock is highlighted as an essential element of production
with no consideration given to the cost of such a system. One needs only
to look to Quebec to see the huge investment required in establishing such
a system. The ongoing costs would also be very high. Certainly there are
benefits to tracing livestock movements, however, is there adequate benefit
to justify such a system? Industry involvement will be critical in the analysis
of cost benefit for options under consideration.
Environmental
Impact
The standardized APF presentation also states that as farms become more
intensified, the environmental impact of agriculture is increasing. There
is limited evidence to show that larger farms have a greater impact on the
environment. In fact there is evidence (Surgeoner, 1991) that shows that
the environmental impact of agriculture has, in many ways, decreased. Discussion
surrounding the APF must focus on agriculture as a positive contributor
to the Canadian economy and the well being of all Canadians. This is in
direct contrast to the suggestion that agriculture is somehow a growing
problem and that the ongoing trend toward fewer and larger farms (a trend
shared by most other industries such as retail, manufacturing, etc), is
somehow at fault.
Interconnection
of Pillars
The risk management pillar is presented as a method of stimulating actions
in the other pillar areas. This can mean many things, including cross compliance.
While there are advantages to drawing the areas closer together, the purest
form of cross compliance (producers only eligible for risk management funding
if they have taken required actions in other pillar areas) would be unacceptable
to many. While it can be seen as incentive, it can also be seen as blackmail.
This topic requires frank and open discussion with industry groups.
Timing
Inappropriate timing of the development of the APF could place existing
programs in jeopardy. An example is the highly successful Environmental
Farm Plan in Ontario. This program, currently subscribed to by fully one
third of Ontario farmers on a voluntary basis, is at a crossroads. Remaining
funding is not sufficient to allow the program to continue until the APF
is finalized and new funds made available. And yet, Minister Vanclief has
publicly stated that every farm in Canada should have an EFP. Careful attention
must be given to this issue as the APF is developed and implemented.
Balanced
Approach
The APF must include recognition of the conflicting nature of individually
worthy goals. An example of this is the practice of no-till farming. Without
a doubt, this management practice is of benefit for soil structure and erosion
control. When focussing on other issues, however, no-till can cause nutrient
management concerns around movement through macropores and increased emissions
of nitrous oxide, a potent greenhouse gas. Agriculture
production, by its very nature, involves a wide variety of production systems
(e.g. grazing versus confinement based). The development of the APF must
recognize this diversity of production systems and balance multiple objectives,
all within the context of cost/benefit analysis.
Communications
Society
Documentation and discussion surrounding the APF does not fully recognize the great deal of work that has been undertaken to date in each of the pillar areas by government and industry alike. There is a tremendous need for all levels of government to work with commodity organizations to communicate to Canadians the importance of having a viable national agriculture sector. This is not branding but, rather, raising the awareness and appreciation by citizens of the reality of farming today, the need for Canadian production and recognition of the many proactive and positive initiatives that industry has undertaken. Examples abound and include the Environmental Farm Plan program, efforts in Nutrient Management Planning, development of Best Management Practices, development of the Livestock Medicines Course. Effective communication with consumers regarding current agriculture practices and initiatives would, undoubtedly, go a long way toward alleviating consumer concerns related to agriculture and food. The development of the APF should incorporate a clear and focussed communications campaign targeting Canadian consumers with messages about current practices as well as new initiatives resulting from APF.Industry
It is important to note that the pillar of science and innovation can only play a contributing role in APF so long as results are effectively communicated to producers. The past decade has seen provincial governments downsize their extension services to a minimal level. While the approach may differ by province, there is a clear need to review extension services and to invest and change where needed to ensure effectiveness.
Funding
Documentation regarding APF speaks of needing to "increase/realign
investments".
To bring the concept of APF to reality, a great deal of additional money
will be needed. The federal and provincial governments must source new funds
to make this happen. There may be some funds available through industry,
however, these represent only a very small portion of the required resources.
Most industry groups are still adjusting to the downloading of services
from government during the last decade. A new initiative such as APF will
require large and ongoing commitment of new government funds. Industry has
benefited greatly from the research and development funds made available
through the current safety nets program. This type of funding should be
continued as part of the APF.
Industry
Involvement
Agriculture commodity groups must have ongoing involvement in the development
of the APF. No one will be affected more than farmers. They must have a
strong voice to ensure that the APF and associated policies will, in fact,
be of benefit to agriculture and not simply a vision that in practice makes
Canadian products the envy of the world yet makes producers unable to be
competitive.