Mr. Chair, let me begin by thanking the committee for your flexibility in scheduling this meeting. I know that you wanted to meet last week, but we were meeting with our provincial colleagues in Montreal. So we're very grateful for that.
[Translation]
It is my pleasure to be here today to provide you with an update on the development of Growing Forward. As you know, the current Agricultural Policy Framework expires on March 31, 2008. In June, federal-provincial-territorial Ministers of Agriculture reached agreement on principle on Growing Forward, the new policy framework for the sector.
Growing Forward identifies three policy outcomes, which will serve as the foundation for policy and program development under the new framework. These policies outcomes are: a competitive and innovative sector, a sector that contributes to society's priorities, and a sector that is proactive in managing risks. Ministers have committed to developing policies and programs under this framework that enable provincial-territorial flexibility, while ensuring the achievement of national objectives.
Regarding the current status, federal, provincial and territorial governments have made significant progress in the evolution towards the new Growing Forward framework. Recently, ministers reached agreement on a new suite of Business Risk Management programing, or BRM, comprised of: AgriInvest, producer savings accounts that provide coverage for small margin declines; AgriStability, the improved margin-based program that provides producers with assistance for larger income declines; AgriInsurance, existing production insurance and other insurance products; and AgriRecovery, the disaster relief framework.
This new suite builds on a commitment by the federal government to replace the Canadian Agricultural Income Stabilization program with new programs that are more responsive, predictable and bankable for farmers.
Federal, provincial and territorial ministers are committed to ensuring a smooth transition from the current APF to Growing Forward. Ministers have agreed to implement the new BRM suite by April 1, 2008. Ministers have also agreed to seek the authorities needed for a transition period of up to one additional year ending April 1, 2009 for non-BRM programming.
During this time, current APF programs would continue until the new programs are established.
[English]
In terms of policy and program development on non-business risk management, the framework builds on and improves on the APF. The framework is outcome-based and more focused on results than the APF. It will support profitability through market returns by taking full advantage of new market opportunities. There's more focus on science and innovation.
Growing Forward will also differ from the APF in terms of program integration. We aim for greater emphasis on client-based services, with more choice for farmers and more streamlined service delivery. In addition, program flexibility will be supported where possible to allow provinces to meet regional needs while achieving common national goals.
Consultations, of course, are fundamental to the development of Growing Forward. Extensive consultations were held from the fall of 2006 to spring 2007 to inform of Growing Forward developments. These included specific sessions on renewal, market development and trade, food safety and quality, environment, innovation and science, and business risk management.
We also had broad-based public engagement with producers and others at a national stakeholders meeting in May. The key message from these consultations was that new directions are needed to improve and sustain prosperity in Canadian agriculture. Canada must build on its strengths, the skills and knowledge of its people, its significant research and development capacity, and a strong protection of modern regulatory systems.
Growing Forward development is also informed by the work of others, and most importantly by the work of this committee. For example, in the response to the committee's June report, the government noted how many of its recommendations were in line with its thinking. For instance, the government recognizes that primary production is critical to the sector and also recognizes the importance of animal health. We also recognize that increasing capacity to support research and innovation within the sector is a key priority. The bio-economy is also an emerging priority, both for the department and for the government.
As for specific policy and program directions in terms of competitiveness and innovation, under the APF spending on science and innovation was relatively modest. Growing Forward will emphasize innovation as a critical component in the long-term competitiveness and profitability of the sector, with a larger amount of resources being devoted to this sector.
As to regulations, while the APF made some headway in addressing regulatory issues for this sector, we're looking at how best to address regulatory barriers in order to promote innovation to ensure that farmers have access to new and innovative inputs and technologies, without compromising the health of Canadians and environmental safety.
During consultations, participants spoke about the need to provide industry with better access to market intelligence and to seek better market access. We're looking at ways to continue to support the development of new market opportunities while continuing to advocate for Canada's trade interests abroad.
In terms of the heading “a sector that contributes to society's priorities”, during consultations we heard about the need to contribute to priorities for safe food, environmental sustainability, and health and wellness. We're exploring with the provinces ways to assist farmers to continue to meet society's high standards for environmental stewardship while enabling them, importantly, to do so in a way that supports profitability and competitiveness.
Federal and provincial and territorial governments are also looking at ways to help the sector respond to market expectations for safe food, in particular through the development and recognition of on-farm food safety systems.
The APF emphasized after-the-fact business risk management, and perhaps a little less, proactive risk mitigation. In Growing Forward, we're aiming to take a new approach to risk mitigation that is more comprehensive and that will assist the sector in preventing risk events before they occur.
As to next steps, Mr. Chair, we will be consulting stakeholders in the development of non-business risk management policies and programs. In November, federal and provincial/ territorial ministers indicated that further grassroots input will be gathered through provincial and territorial consultations, followed by national consultations early in the new year. This next round of consultations will happen quickly, since we need agreement on business risk management programming by March 2008.
I would like to thank you for allowing me to make these comments. We welcome the committee's questions.
:
Thank you, Mr. Chair, and thanks to you departmental folks for coming.
Andrew, you went to fairly substantive length talking about the new business risk management program and said that you're looking at April 1, 2008. The reality is that if nothing is done by way of a cash infusion, especially for the hog industry, and to a certain extent for the beef industry, there will be one hell of a lot of folks not here by April 1 in those industries.
I don't know, but I'm sure government members as well have to be getting e-mails, correspondence, telephone calls every day about people going broke in the hog industry. In my riding alone, nine people have gone out; that's 130,000 pigs on an annual basis. These are third-, fourth-, fifth-, and sixth-generation farms, some of them having been recognized as farms of excellence in the past. These are the folks who are going under in this current crisis. My worry is, we're sitting here talking while Rome certainly burns for those two commodities.
Today in the House during question period, the Secretary of State for Agriculture said money would be forthcoming to the beef and hog industries. I have two questions about that. When is this money forthcoming? Under what program is it coming? Don't, for heaven's sake, tell me it's the same $600 million that's been announced three times already.
Secondly, will this program you're talking about today meet what the Prime Minister said on April 6, 2006, when he made the promise of cost of production? Will this program we're talking about today meet the actual cost of production, or will it not? What about the money for beef and hog producers that the parliamentary secretary mentioned? What program is it under, and when will we see it?
:
Thank you for that question.
Maybe I'll begin, and Danny can supplement my answer.
On November 17, the federal and provincial ministers met in Toronto and struck an action plan to address the very difficult circumstances being faced by the cattle and pork industries. They set out a number of principles that should guide the approach, including a nationally coordinated approach, an approach that is in line with our trade obligations, an approach that supports long-term sustainability, among other things.
Since that time, we have continued discussions with the livestock industry at a federal and provincial level. We met with the industry two weeks ago in Montreal, and again this week in Montreal met with federal and provincial deputy ministers.
The ministers outlined an approach that first of all looked at accelerating access to moneys under existing programs. There are significant moneys available under those programs, but we recognize it as important that they get out to producers very quickly. We're also looking at where the gaps are in those programs and how we can address those gaps identified.
We are engaged on the issue with the industry. I can't comment on what the response will be, but we are moving forward with existing programs and we are looking at where the gaps are.
The issue, as the industry has characterized it to us, is an issue of liquidity—immediate liquidity. The industry hasn't asked us for ad hoc programs. They want us to address the liquidity issue through existing programs or other alternatives that they have put forward.
They'd also like to look at a long-term approach, by addressing regulatory issues. We have been examining those with a federal-industry task force. It's a complicated issue. It's been noted by many people that it's a very difficult situation facing the livestock industry, a confluence of events close by—obviously, the effect of the dollar, but also effects of the pressures caused by feed prices and other issues, and by the cyclical nature of the industry and the point we find ourselves at in that cycle.
Danny, do you want to add to that?
:
To be specific to the question, we haven't done that comparison back five years and basically profiling farmers by size, but we have looked at what the new business risk management suite will do for farmers in terms of specific responses. For example, with respect to the situation in the hog industry, the AgriStability program will provide significant support to that industry, and I think you would hear the same response from the industry itself.
In fact, we've started issuing targeted advance payments under the AgriStability program to producers where Canada delivers, and the provinces requested that. I can tell you that the amount of assistance being offered under that approach is significant to the hog industry.
As well, when provincial ministers sign on to the new AgriInvest program, which we're expecting within the next two weeks, we will then be able to launch the Kickstart program, which is the $600 million, and that money will be available early in the new year for producers—not just livestock producers, but that's who we're talking about here today—and then the AgriInvest program will kick in once they complete their tax information for the 2007 year.
But the AgriStability program is up and running. Interim payments are available to producers under that program, and targeted advances, which are a new tool available to producers, are in place in a number of provinces. They've been delivered in Alberta. The letters are now in the hands of Manitoba producers, and in New Brunswick and Nova Scotia as well. The provinces of Saskatchewan and B.C. are considering a similar vehicle. ASRA has delivered most of the assistance in Quebec, and Ontario at this point is promoting the interim payment mechanism versus the targeted advance mechanism. This is actual support going to producers.
There is another program that helps producers with cash flow and assistance. That's the federal advance payments program, which, as you know, we've recently expanded to include livestock, including hogs and cattle. That program is available to producers in a number of provinces. In a number of provinces—I think three or four specifically for hogs—we're still negotiating delivery arrangements with provincial organizations.
Those programs are up and running, and as I said, once we've got the agreements signed with AgriInvest, we can start to flow funds through the $600 million Kickstart as well.
:
Thank you, Mr. Chairman.
I was advised to ask you the following questions. I know the agricultural sector fairly well and I will continue with the same issue raised by my colleague Wayne.
Some witnesses told the standing committee that bureaucrats are keeping them in the dark about the details of the new BRM programs. Could you provide to the standing committee before the end of December all the available details on how these programs will operate?
These programs will come into effect in January 2008, or perhaps in April, but nobody knows what is happening. It doesn't make any sense. As was said earlier, this is not a situation of an employer versus an employee, but rather of a government versus producers who are in a crisis. Why has nothing been announced? I don't know who will want to take the question, but there it is.
You met on November 17 to move things forward. The industry did not ask for anything. If you wait for everyone to speak up before doing anything, every producer will declare bankruptcy, and that will be the end of it. Is that what the government wants? I do not know. It's all very well and good to toss out numbers, like 600 million dollars, but things have to happen now.
Last year, I asked officials from the Department of Agriculture to explain the vision of the government. But until now, I have not received an answer. I believe there must be a long-term vision for the agriculture sector, as for any other sector. Primary resource sectors are essential. If agriculture is suffering, the entire country will suffer; there is no doubt about it.
I would like to receive an answer on that matter.
:
Yes, of course. The three big non-business risk management programs under the APF that applied at the farm level were the environmental farm planning and best management practices aspect of environment, which involved essentially farmers engaging in a planning exercise to look at the environmental risks associated with their operation, and then assisting in addressing those through best management practices.
We saw take-up of those programs really take off under the APF, beyond what we had predicted. I think we had, at last count, about 70,000 environmental farm plans in place, and as we went through the consultations we saw a desire to continue—perhaps adjust those programs, but continue in them. What we're looking for is to roll that kind of program into an integrated approach, where we do the environmental farm planning, the food safety, and renewal-type business management programming in a suite of programs, so that we can address it, rather than by having three or four or five or six people coming onto the farm with different programs, with one approach, where you'd look at the whole and then plan over a period of years how to implement those kinds of practices.
As I mentioned, the environmental farm planning was quite successful, and we've seen as we talk to producers a real interest in pursuing it. That's an interest shared by most, if not all of the provinces, so we'd be looking to continue it.
In terms of food safety, we had a lot of emphasis on building recognized food safety systems commodity by commodity. We have about 16 out of 19 commodity groups who have reached the stage of almost having those systems recognized, this work being led very much by producers. I think the discussion as we go forward with Growing Forward will be about how we implement those, reflecting the demands being placed on producers by the marketplace to put in place HACCP-like systems and so on.
Then, on business management practices, there have been a lot of discussions and consultations about how we can best provide those services to producers.
In general, those are the three types of programming we sell and the focus of the discussions going on.
:
Thank you very much, folks, for being here.
Before I start, I'd like to apologize to my colleagues. It took me three days to get here from my home.
The main theme here that I want to look at—and I'm glad you folks are here—is the whole idea of producer involvement and the effect on producers.
The first category is biofuels. I'm just wondering how much incentive there is in producer involvement in this new strategy, or is a lot of the subsidy going to multinationals to set up so that they can provide jobs and provide a place for grains? I'm just wondering how carefully this is examined.
I know, the more research I do, that there are concerns with the whole idea of ethanol from corn, ethanol from sugar, the input/output, the energy, and the greenhouse gases. But at the same time, we know this is a way of helping farmers. We know this, and we're seeing some results.
I'm wondering what the long-term strategy is, especially as far as a farmer is concerned, in the whole idea of a safe environmental strategy for biofuels. We're moving into the whole APF, and I see it's been broadened to include the agri-based products industry. I'm wondering where the primary producer fits in. We often see the term “industry”, and I'm just hoping this isn't at the expense of the primary producer.
This is my last question. In the last few months, I've had an immersion in the whole issue of food security, from a conference in my town of Nelson in my district, to the NFU conference, to a meeting last Thursday—a dinner sponsored by the OFA and others.
The whole talk now is about the future of food and food security and the studies that have been done—and we mentioned it in our report, as our last recommendation—and yet the whole issue of trade obligations comes up. I'm wondering whether we can really have a food security strategy in Canada, when we have these trade obligations, to promote buying locally and promote the primary producer without being squeezed by NAFTA or the WTO, because that's another issue that seems to be coming up.
That's my question. How can we have a food-secure nation, meet our trade obligations, and make sure that the primary producer benefits from this?
:
Thank you for the question. There are a lot of issues there. We could probably spend a lot of time discussing them.
But very briefly, in terms of biofuels and producer participation, I think it's clear that the whole biofuels and bio-products area offers tremendous opportunities for producers. We're seeing that play out already.
The government announced a couple of programs to assist producers to participate in this. The Biofuels Opportunities for Producers Initiative was a $20-million program to help farmers develop business plans and feasibility studies to look at participation. Then, the ecoABC program, or ecoAgriculture Biofuels Capital program, is a $200-million program to provide matching funding for producer participation in the development of biofuel facilities.
So there are programs in place to help producers participate not just in the growing of feed stock but in processing it into fuels. This is part of the overall biofuels strategy that has been announced. There are other components, but I won't go into those now, in the interests of time.
As to bio-products, I'm going to pass that to Dr. Fortin in a moment.
On the whole issue of food security, in the consultations on Growing Forward we heard a lot of interest in growing the domestic market and in recognizing it. We export about 43% of what we produce, depending on how you count it. So for large parts of the sector, the export market and the global market are critically important for their success. But there are opportunities in Canada, and that came out in the consultations.
We developed, under the APF, a Brand Canada initiative, which is to understand our global customers—what they like about Canada, what they see as important—and to demonstrate to them that we're close to the top, if not the top, in those areas of food safety, quality, environmentally responsible production, and so on.
A lot of those messages resonate in the domestic market, and there are opportunities, as people pointed out in the consultations, to take a greater share of that domestic market for our producers. In that context, it can be consistent with our trade obligations. Where it's not consistent is where we put up barriers that are not allowed under the various agreements we're party to.
Concerning bio-products, perhaps Dr. Fortin would like to comment about the future.
To follow up on what Mr. Easter asked you, like him and I suspect all other members of the committee—and I dare say all members of Parliament—I am receiving emails from beef and pork producers. Such as they exist in my small urban/rural riding, I've heard from, I dare say, all of them. I say this with no disrespect, Mr. Marsland, intended towards you, but these folks want some immediate and some concrete answers. Discussion is continuing, and that's nice. Industry is engaged—okay. An action plan has been struck—all right. But those sound rather futuristic, or “at some point in the future”. We've heard presentations by cattle producers and hog producers, and we've heard—no sarcasm intended—that cash by Christmas is what's required.
You've talked about “interim advance” potential, and “targeted advance” potential. You'll surely know that the Canadian Cattlemen's Association is requesting, à la 2004, a special advance, and I presume you're familiar with the formula they have.
I want to have, if I may, not a yes or no answer, but a cogent, tight answer as to whether these producers can expect a special advance, and if so, how it will be calculated and when it might actually be received by them.
:
Just to correct the record, I might mention that Mr. Boshcoff said the Wheat Board is not a supply management program.
Witnesses, thank you for being here.
I want to just share a little experience I had last Thursday and Friday, and maybe afterward get your comments. I had the opportunity to be in P.E.I. and Nova Scotia, and I met with a number of farm groups, some government officials, some agriculture ministers, the Premier of Nova Scotia. I was really pleased to see how well I was received, how well Growing Forward was received.
Actually, at one of the conferences I attended, the motto—that's not the right word—that day was “transition to profitability”. All of them acknowledged the difficulties in the pork and beef industries, but they said, “We really feel that the department is putting farmers first”. They actually used that term. They talked about a transition to sustainability, they talked about profitability. I was really pleased.
The other thing they talked about is that finally—
:
Good afternoon to everyone.
I am pleased to be here with you today. As you know, I am the newly elected member for the riding of Saint-Hyacinthe—Bagot, a riding which has at its heart a own which is an agrifood technopolis. At one time, the agrifood business was my livelihood. I operated a hog farm for over seven years in the 1990s. In fact, I am the grand-daughter of an agronomist. So it goes without saying that this sector is dear to my heart.
I would be very pleased to welcome my colleague Mr. Lauzon in my riding of Saint-Hyacinthe—Bagot. As for what you heard on Prince Edward Island, let me show you that it is not what I am hearing on the ground in my riding. Indeed, 25% of the jobs in my riding are directly related to the agrifood sector, and, as we speak, producers are being squeezed out. You said that producers told you that they were happy with the money provided under these programs. However, it is as if you were giving five dollars to someone who needed ten. Of course, producers will take the money. But the fact remains that it is not enough. Much more money must be made available. We need more than answers: we need concrete measures to support the agrifood industry.
How do you explain that the AgriStability program is still using an olympic average, despite the fact that it was one of the most criticized measures under CAIS. Why has this flaw in the program not been corrected yet, and when will it be?
:
With respect to the AgriStability program, you're right. The reference period, if you will, is based on what we call the Olympic average. So we look at our producers' margins for the previous five years, drop the high and low, and average the remaining three.
We had an option to do that or to look at just the previous three years. We are bound by WTO rules, so we can report the dollars under the disaster portion of AgriStability as green for WTO purposes so that we can stay within the $4.3 billion that Mr. Miller referred to and meet our WTO obligations.
If we had our druthers, we'd probably be looking at a five-year reference period, looking at the previous five years, because when we've consulted with producers in the past, they said that's probably the best reference period you could use.
You don't want to go too far back because then you're not reflecting what the current reality is in the market, but you don't want to have it too short because then you have too much variation in your level of support.
So we said five years, and then we were bound by what the WTO requires so that we can report this money as green for trade purposes and not amber. Based on our analysis at that time, the Olympic average was found to be the best. We are staying with the Olympic average going forward under the AgriStability program.
There have been suggestions from both the hog and the beef industry to give producers the higher of the previous three years or the Olympic average. We are looking at that. It wouldn't benefit all producers, but we need to assess that from a cost and a principle standpoint. That's part of what the industry has proposed going forward.
:
Thank you for the questions.
On the issue of disaster relief and response, on November 17 the federal and provincial ministers did agree to an approach to funding small and medium-sized disasters on the usual 60-40 basis.
I'm sure Danny can provide the criteria that are there, but essentially, they distinguish between a large disaster and small disaster. There's no specific dollar amount, but a series of criteria that apply. If it meets these criteria, then it's a small or medium disaster; therefore, it will be funded on the 60-40 basis.
In terms of the interprovincial trade barriers, we have a standing group of federal-provincial assistant deputy ministers and deputy ministers as well as the regular meetings of federal-provincial ministers. Discussions on chapter nine of the agreement on internal trade have been ongoing for the last couple of years, and we've looked at ways of moving forward on that. As you will know, I think the federation made a resolution on this, the provincial premiers, that they wanted to move forward on this, and we've been looking at ways of dealing with that. We continue to do that and we facilitate those discussions between the provinces as much as possible in looking for a way forward.
:
One concept that is gaining a fair amount of popularity and is being studied more intensively is the concept of bio-refineries. You wouldn't extract a single product out of a single plant. A typical plant might contain something like 40,000 different compounds that have been synthesized, essentially, through water and solar energy.
Can we extract more value out of a plant than a single compound? We need to undertake more detailed studies as to what products can be extracted, what markets there are to push those markets out of the farm gate, and what processes need to be created to extract that value out of the crops and create new products with them.
What is emerging out of the studies that are being done across the country and across organizations--not only AAFC, but also organizations like Natural Resources Canada, National Research Council and others--and from academic studies in the university sector, is that we will have to adapt a variety of feedstocks to a different set of products and market realities.
It's unlikely that we can develop only a single feedstock, a single plant, to address the variety of market opportunities that are out there, and that's precisely why the agriculture biomass innovation program aims at developing different feedstocks for a different range of products. Each country will have to find its own feedstocks in relation to potential markets and in relation to the potential for growing that feedstock.
No one in Canada has yet put his or her finger on a single feedstock that will answer all solutions, that will provide all solutions to all sectors, to all kinds of products. People are talking about bioplastics, biomaterials, composites, replacement chemicals, displacing fossil fuels, and producing chemicals from biomass. There's a great deal of uncertainty yet in that sector, and we need more work.
:
Danny, you mentioned the AgriStability advance document that the banks are willing to look at almost as collateral. Can you provide members with a copy of that when you get back to the office? I think that's a very good idea, and a lot of people don't know it's available.
The committee in its recommendations—at least on this side of the House—wasn't overly enthused with the department's or the minister's response to our spring report. We thought it was vague and unclear. In recommendation 16 we recommended that a billion dollars be set aside in a federal contingency fund for disaster relief, such as the situation we have right now with hogs and beef. The response basically said that time and again the federal government has demonstrated that it will respond to emergency situations. Examples given were BSE, golden nematode, and avian influenza. That's true, but we have a disastrous situation here right now where the government isn't responding with special programming, as was mentioned by one of my colleagues earlier.
Andrew, you mentioned that the organization leaders said they don't like ad hoc programming, or they are against it. I can tell you that the producers I talk to want ad hoc funding. They want money in their pockets right now. I have been to several bankruptcy sales in the last six weeks—people I've known all my life, third- and fourth-generation farmers. They don't give a damn whether the ad hoc program is trade viable or not. They need some cash in their pockets to keep them going, and it just isn't happening.
If we weren't challenged on the $1.6 billion, or thereabouts, that the previous government put into BSE under 10 or 12 different programs, why would we be challenged on ad hoc moneys going for hogs and beef right now when they direly need it?
I have a second question, and somebody can think about it while Andrew is answering the first. I was confused—those guys will say that isn't unusual—by your answer on AgriInvest in relation to supply management. How will AgriInvest work for producers of supply management? Be fairly specific if you can.
Before continuing, my colleague across the way is gone, but I wanted to remind him that in the past, at least since I've been with this committee, we've worked quite well together in spite of our differences, and we were here for farmers. I don't think cheap political shots are appropriate.
I thought I'd record that for the record. In a hundred years, when somebody reads this, they'll hear my words.
I would like to continue with this. We've seen a report. We've seen your response to the report. There are a number of items, food security or other areas, and you folks have mentioned it, this whole idea of trade obligations. It seems like a black cloud hanging over Canada that we have trade obligations.
Other countries don't seem to worry about that. Europe has put a quota of 0.5% for pork coming in, and we're being asked to increase our quota from 5% in Canada. Americans always slap something on us, and we're always worried about trade obligations.
Can we not move forward and get to the bottom of what's happening in our agricultural sector and worry about our path, our farmers, and our primary producers without always having this hanging over us?
What happens if we move into this area in a little bit? That's the first question, and I would like to get some feedback on this.
I think you know when we talk about the sector we sometimes talk about it as one, but it is a multi-faceted sector and various parts of the sector depend to a greater or lesser extent on exports.
In the supply-managed area we have a made-in-Canada system, which is very much focused on the domestic market, that works well for the country.
In other parts of the sector they rely on exporting more than 50% of what they produce, but overall, trade is very important for the country. As I mentioned, I believe 43% of production is exported, so it's important that we have a world trading system that serves us well. We have been pressuring for improvements in that system, as you know.
For other countries, we have been firm in insisting other countries respect their trade obligations. As you recall, we have requested a panel to look into subsidy practices in the United States.
So I think trade is critically important for the sector, and we need to look at it both in terms of respecting our obligations in a defensive way but also making sure other countries respect theirs.
:
Thank you, Mr. Chairman.
Thank you to the witnesses for coming in.
The reality, Mr. Atamanenko—and this is not a cheap shot, quite honestly—is that we would be missing many of these discussions if the former programs were still in place, the NISA program and provincial programs that were its counterparts. Since we lost those, we've now ended up with a CAIS program, which is a terrible program that is not fair.
I think we all understand that when a program is in place, it is much easier to leave it in place and work within the parameters of that program, to keep it in the green box, or as an acceptable and unchallengeable program in terms of trade barriers. We've lost that. That's a fact.
So now we're dealing with a new program that was CAIS and now we're working with a target of business risk management programs that will take us in some direction, even though they still have a margin-based program.
So one of my questions to the panel would be, in terms of the margin-based program, how much of the fact that those programs are staying in place with a margin base is provincially driven?