Kernel Visual Distinguishability
Res #: 390-03A
Responses Received: No
Departments: Agriculture and Agri-Food Canada
Resolution No. 39E1-03A (Emergent)
WHEREAS, the Canadian Grain Commission (CGC) is proposing to add Variety Eligibility Declarations (VED) to deal with unlicenced varieties to the existing grain classification system known as Kernel Visual Distinguishability (KVD) and the subsequent relaxation of KVD; and
WHEREAS, the changes being proposed could affect our standard of quality and it is imperative that Canada’s reputation as a consistent supplier of high quality wheat be maintained; and
WHEREAS, consultations on VED began in January 2003 and are scheduled to end March 31, 2003, and this is not enough time to have meaningful, widespread consultation on such an important issue; and
WHEREAS, the proposed VED system would increase producers’ costs, but a cost/benefit analysis has not been done to determine these costs; and
WHEREAS, the CGC has not been able to enforce the Canada Grain Act in the past when unlicenced varieties of grain have been delivered into the elevator system, and the new proposal is silent on both enforcement and penalties that would be associated with misrepresentation;
THEREFORE BE IT RESOLVED, that any changes to the present KVD system must reflect a costing formula and the principles of quality control and accountability with reasonable time for consultation; and
BE IT FURTHER RESOLVED, that enforceabilty problems may need to be addressed by amending the Canada Grain Act.
Response from the Honourable Lyle Vanclief, Minister of Agriculture and Agri-Food Canada:
Thank you for your letter and the enclosed resolutions passed by your members at the Saskatchewan Association of Rural Municipalities' 2003 annual convention. I appreciate the opportunity to address your correspondence which clearly highlights the priority issues facing Saskatchewan's agricultural producers. I regret the delay in this response.
With respect to your resolution on the Variety Eligibility Declaration (VED) proposal, I want to inform you that, as of March 31, 2003, the Canadian Grain Commission (CGC) completed initial consultations regarding the proposal. I understand that the Saskatchewan Association of Rural Municipalities actively participated in the consultations by meeting with CGC officials, by providing representation at a focus group held in Regina and by making a submission on this issue to the Commission. Your input and the contributions of others will be considered when decisions need to be made regarding the proposal.
One of the underlying objectives of the VED proposal is to strengthen Canada's grain quality assurance system. As you pointed out, Canada's reputation as a supplier of high quality wheat is dependant on the integrity of this system, and changes to this system would only be considered after widespread consultation and thorough study. The CGC recently announced the next steps in the evaluation of this proposal – the first of which will be a cost-benefit analysis. The achievement of a net benefit will be one of the key considerations before major changes are made to the grain quality assurance system.
The issue of accountability and enforceability will also be addressed. It is not yet clear whether the Canada Grain Act will need to be amended; however, an amendment to the Act would be necessary of a regulatory system is ultimately supported. Under the current legislation, the CGC does not have the authority to take any action with respect to non-registered varieties other than to downgrade a specific lot of grain. The next phase of this initiative will also include the evaluation of potential alternatives that were proposed by stakeholders during the consultations. I
t is possible that an alternative system or a combination of initiatives may be preferable to VED. After conducting the above-mentioned analysis, the CGC will report back to, and consult with, stakeholders before any decisions can be made. The current target time frame for a second phase of consultation activities is fall 2003.