July 18, 2016
Gerald Kamenz, Chair
Farm Products Marketing Commission
Ontario Ministry of Agriculture, Food and Rural Affairs
1 Stone Road West
Dear Mr. Kamenz:
FBO appreciates the opportunity to provide input on the proposed amendments to Regulation 440. We are pleased that the Commission views each of Ontario’s value chain separately, and that it is prepared to provide oversight on an individual basis, and in support of the entire value chain.
Ontario’s processing vegetable sector’s regulated marketing framework is in need of a substantial refresh. FBO appreciates that the changes proposed are significant and indicate the Commission’s commitment to substantive change within this vital Ontario agri-food industry.
In Support of the Premier’s Agri-Food Challenge
FBO supports the Commission’s efforts in support of the Premier’s Agri-Food Challenge and Minister Leal’s Mandate Letter. In October 2015, the Agri-Food Growth Steering Committee delivered to Minister Leal advice on how best to support industry in meeting the Premier’s Challenge. Within the committee’s recommendations several key actions/goals/objectives were stated:
- Increasing the competitiveness of Ontario’s agri-food businesses;
- Enhancing activities to attract and retain agri-food investments, to grow our domestic market shares and drive exports;
- Reducing regulatory burdens;
- Identifying new opportunities for growth along the entire agri-food value chain;
- Addressing barriers to growth that impact retention and attraction of agri-food investments in Ontario.
FBO believes that the Commission’s proposed changes to Regulation 440 will provide the industry with support in addressing the key elements that were noted by the committee, and will result in an improved environment that will allow Ontario’s processing vegetable sector many new opportunities to grow, attract new investment, and create jobs for Ontario.
Modernizing Ontario’s Processing Vegetable Sector
FBO also supports the Commission’s view that modernizing the procurement system for processing vegetables will enable Ontario’s processing vegetable sector to remain viable and grow.
FBO is not opposed to regulated marketing of agricultural products, and in fact we support it when it brings value to an industry. However, regulated marketing in Ontario must meet the needs of the entire agri-food sector, and outdated regulations are a major barrier to innovation in Ontario’s food and beverage processing industry. FBO welcomes the Commission’s efforts to modernize the processing vegetables sector through the proposed changes to Regulation 440.
FBO also supports the Commission’s proposal to allow for the establishment of an industry advisory committee, and to make additional amendments to the board’s powers.
Regulation 440 delegates significant decision making authority to the producer board. This may have been reasonable in the 1940’s when the provincial marketing plan was set up, , as at that time the issues dealt with by the board primarily impacted the producers it represented. However, the Ontario processing vegetables industry has evolved over the years to a point where today, decisions made by the producer board pursuant to its delegated authority go well beyond the matters affecting just the farmers they represent. FBO supports the Commission’s proposed changes that will allow for a broader industry based approach to policy development and decision making in this sector.
In order to build a healthier industry, respond to evolving customer and consumer needs and expectations, and develop true industry partnerships, it is imperative that Ontario’s regulated marketing system for processing vegetables system is reformed to keep pace with the environment in which the sector as a whole operates.
Michael Burrows Norm Beal
Cc: Deputy Deb Stark, OMAFRA