November 21, 2017

Hon. Wayne Easter, Member of Parliament Chair, House Standing Committee on Finance Sixth Floor, 131 Queen Street House of Commons Ottawa, ON

RE: Proposal for a Trusted Employer Program

Dear Mr. Chair:

Labour has a major impact on Canadian fruit and vegetable production. Without an adequate workforce to grow and harvest it, produce rots in the field, on the three, or on the vine, resulting in waste and financial lost. The Canadian Horticultural Council (CHC) represents fruit and vegetable growers across Canada involved in the production of over 120 different types of crops on over 27,500 farms, with farm cash receipts of $6 billion in 2016. Since 1922, in collaboration with members and the government, CHC has advocated on important issues including labour.

Canadian producers hire Canadians first and conduct ongoing and vigorous recruitment. When producers are unable to find enough Canadian workers, they access the Seasonal Agricultural Worker Program (SAWP) or the Agricultural (AG) Stream of the Temporary Foreign Worker Program (TFWP) to address their labour needs. While producers and workers currently benefit from these programs, certain improvements could be made to further advantage workers, farmers, and the economy.

Canada’s fruit and vegetable industry urges the federal government to implement a Trusted Employer Program to help streamline and standardize the Labour Market Impact Assessment (LIMA) application process, as per the HUMA Committee report. This proposed program aims to achieve the following: 1) reduce the regulatory and administrative burden on employers in good standing using SAWP / TFWP AG Stream to fill current labour gaps, and 2) facilitate the mobility of workers between Trusted Employers during harvest seasons.

In order to be eligible to apply for Trusted Employer status, an employer would have to have used either SAWP or TFWP AG stream for five consecutive years and be in good standing with Service Canada throughout this time. This requirement would provide enough time to establish a pattern of behavior required to be eligible for the program and would demonstrate the continued domestic labour shortage.

To ease both the SAWP and TFWP AG Stream administrative burden, those who qualify as a Trusted Employer should not have to re-submit all their paperwork with every LMIA application. Where possible, LMIA application forms should be pre-populated with previous years’ information, much of which will remain the same year after year.

Further, farms currently have to advertise a position for two weeks, despite the lack of interest from Canadians to apply. Only when no applications for the position have been submitted by a Canadian, should a farmer be able to then move ahead with hiring foreign workers. We recommend that the

1 advertising time be reduced to one week for Trusted Employers, in order to expedite the process of hiring foreign workers, provided there are no interested Canadians.

Lastly, we strongly recommend that workers under SAWP or TFWP AG Stream be able to move between Trusted Employers’ farms on a short term basis, when and if required, provided that proper notification is given to Service Canada, the provincial farm labour management services, and the supply country Liaison/Consulates. This labour mobility would allow farmers to maximize labour in the surrounding area during peak times and/or provide opportunities for SAWP/TFWP AG Stream workers whose employer has been impacted by poor weather, other environmental impacts or a lull in harvesting.

CHC has worked with the Canadian Agricultural Human Resources Council and the Canadian Produce Marketing Association to develop the proposed model and ensure it would be successful. We hope this model can leverage the current framework established by the government on a number of different trusted programs, including the Trusted Trader program and the Trusted Traveler program, and reduce administrative burdens for both the government and employers. We strongly believe that the implementation of such a model will address some of the major labour gaps facing agriculture in Canada and work towards the government’s goal of increasing agri-food exports by 2025.

I’ve taken the liberty of attaching CHC’s original pre-budget submission to FINA, which includes other recommendations, such as: a National Tree Fruit Investment Program, increased funding for the Canadian Food Inspection Agency and Pest Management Regulatory Agency, and a carbon pricing exemption for greenhouse vegetable growers.

As FINA moves forward with recommendations for Budget 2018, I would be pleased to answer any questions you have regarding the proposed Trusted Employer Program or any of our other requests in our original submission.

Sincerely,

Rebecca Lee

Encl.: CHC Pre-Budget 2018 Submission to FINA CHC National Tree Fruit Investment Program

CC: Hon. Pierre Pollievre, MP Pierre-Luc Dusseault, MP Dan Albas, MP Greg Fergus, MP Raj Grewal, MP Kamal Khera, MP Tom Kmiec, MP Joël Lightbound, MP

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Michael McLeod, MP Jennifer O’Connell, MP Francesco Sorbara, MP Pat Finnigan, MP Luc Berthold, MP Ruth Ellen Brosseau, MP John Barlow, MP Sylvie Boucher, MP Pierre Breton, MP Francis Drouin, MP Lloyd Longfield, MP Eva Nassif, MP Joe Peschisolido, MP Jean-Claude Poissant, MP

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