Proceedings of the Standing Senate Committee on
National Finance

Issue 29 - Evidence - March 31, 2015

OTTAWA, Tuesday, March 31, 2015

The Standing Senate Committee on National Finance met today at 9:30 a.m. to give consideration to the substance of Bill C-21, An Act to control the administrative burden that regulations impose on businesses.

Senator Joseph A. Day (Chair) in the chair.


The Chair: Honourable senators, this morning we will begin our study of Bill C-21, An Act to control the administrative burden that regulations impose on businesses.


Honourable senators, this morning we are very pleased to welcome Mr. Dan Albas, M.P., Parliamentary Secretary to the President of the Treasury Board.

Dan Albas, M.P., Parliamentary Secretary to the President of the Treasury Board: Thank you, Mr. Chair.

The Chair: Mr. Albas is accompanied by Michael Vandergrift, Assistant Secretary, Regulatory Affairs, Treasury Board of Canada Secretariat.

Mr. Albas, we thank you very much for being here. I would ask you to introduce the bill to us, and then maybe we'll go to Mr. Vandergrift to look at a clause-by-clause type of analysis. It's a short bill, and you could tell us what each of the clauses is intending to achieve.

Mr. Albas: Absolutely.

Mr. Chair, members of the committee, I would like to thank you for the opportunity to speak about Bill C-21, the red tape reduction act.

As the chair mentioned, I have with me Michael Vandergrift, Assistant Secretary, Regulatory Affairs at the Treasury Board of Canada Secretariat.

The bill being considered by the committee, Bill C-21, enshrines the government's one-for-one rule into law and will help permanently control the growth of the federal regulatory red tape.

This rule has actually been in place for almost three years, and it's the cornerstone of the government's Red Tape Reduction Action Plan, which was launched in October 2012 to eliminate unnecessary federal regulations while maintaining high standards for public safety and protection.

The purpose of the rule is to make regulation as pain-free and efficient as possible for Canadian businesses, and to free them up to do what businesses do best, which is grow, innovate and, of course, create jobs.

Specifically, Bill C-21 would enshrine the two core elements of the one-for-one rule into law.

Regulators must offset cost increases and administrative burden on businesses, and they must remove a regulation each time they introduce a brand new one that adds administrative burden on businesses. This approach has already proven to be effective. Since its implementation, the rule has provided a successful system-wide control on regulatory red tape impacting businesses.

As reported in the Red Tape Reduction 2013-2014 Annual Scorecard, the rule, as of June 2014, has resulted in a net annual reduction of more than $22 million in administrative burden on businesses, an estimated annual savings of 290,000 hours dealing with regulatory red tape and a net of 19 federal regulations taken off the books.

So the one-for-one rule and other red tape reforms are building and bringing a new level of discipline to how the government regulates and creates a more predictable environment for businesses. And we're doing it while maintaining high standards for safety and protection for Canadians.

As the preamble to Bill C-21 states, the one-for-one rule will not compromise public health, public safety or the Canadian economy. Further, having the added force of legislation indicates that this culture change in bureaucracy has the weight of Parliament behind it.

By giving the rule the added force of legislation, Canada will now be one of the first countries in the world to legislate a one-for-one rule to control red tape.

Mr. Chair, our approach is designed to increase Canadian competitiveness, to free business to innovate, invest and create jobs without being impeded by unnecessary government regulations.

Let me give you one example from among many of how the rule works. Public Safety Canada recently amended the government's Accounting for Imported Goods and Payment of Duties Regulations. It increased the threshold from $1,600 to $2,500 for shipments to qualify under the Courier Low Value Shipment Program and benefit from a streamlined process. In fact, this allows courier companies to use a consolidated document for the release of imported goods instead of a document for each shipment, and importers will no longer have to present release request entries or manifests to their local Canada Border Services Agency office to obtain the release of those goods.

Allowing more shipments to be processed through the low-value stream is expected to save businesses about $700,000. The exact number is $688,221 in administrative costs a year.

Now, there are many other examples just like this across government, and of course they all add up.

Mr. Chair, with Bill C-21, and by following through on our other red tape reduction commitments, the government is hoping to cement Canada's reputation as one of the best places in the world to do business and invest.

Some of the other commitments the government has include posting forward regulatory plans on the Web, creating service standards for high-volume regulatory authorizations and keeping track of our progress — a very important thing we all agree with — in reducing red tape through the annual scorecard report. In fact, by enshrining the one-for- one rule into law and by moving ahead with other measures to control red tape, we are helping to create the right conditions to support the success of Canadian businesses in a very competitive world.

Measures such as these, which support business without compromising public health and safety, help position Canada for long-term economic prosperity.

We are pleased to present the bill to committee for consideration. Mr. Chair, I'm at the committee's disposal.

The Chair: Mr. Albas, thank you very much.

Mr. Vandergrift, could you focus us on the bill for a short while, since that is what we will have to focus on when we do a clause-by-clause analysis.

Michael Vandergrift, Assistant Secretary, Regulatory Affairs, Treasury Board of Canada Secretariat: Thank you for the opportunity to be here. It's a relatively short bill. I will quickly walk through the clauses. It starts off with a preambular section, and there are four components to the preamble.

The first essentially outlines the main objective of the act, which is to address unchecked and increasing administrative burden costs.

The second preambular clause establishes that the rule has been in effect by policy since April 1, 2012, and is now proceeding to be implemented through legislation, but there has been some experience prior with this rule given that it's been implemented through policy.

The third is to enshrine that the rule shall not or must not compromise public health, public safety or the Canadian economy. This is a guiding principle for the implementation of the rule.

The fourth establishes the importance of transparency in implementing the rule and the transparency in the regulatory system itself.

Clause 1 provides the short title for the act, which is "Red Tape Reduction Act."

Clause 2 provides the definitions for the act, and the first one defines "administrative burden." This is the definition of the cost we are controlling under this rule. The second is the definition of "business." Regulations that impact business are within the scope of this rule. Third is a definition of "regulation." Regulation is defined in the Statutory Instruments Act. These definitions set the parameters and scope of the application of the bill.

Moving to clause 3, this act applies to regulations made or approved by the Governor-in-Council, the Treasury Board or a minister. This defines the scope of application.

Clause 4 sets out the purpose, again to control the administrative burden, as I mentioned in the preambular statement as well, to control the burden of regulations that they impose on businesses, so you see those definitional terms earlier start coming back in the provisions of the bill.

The two main components of the rule are laid out in clause 5. Clause 5(1) establishes that if a regulation imposes a new administrative burden on business, then the minister must amend or repeal a regulation to offset the cost of that new burden. The administrative burden is costed, using the standard cost model, and ministers are required to offset that equivalent amount of a cost by changing another regulation.

The second component of the rule is that if a new regulation is made that imposes a new administrative burden on a business, a minister must repeal another regulation. So this is where you have a repeal of a title, a regulatory title. Those are the two components of the rule laid out in clause 5.

Clause 6 provides the authority for the President of the Treasury Board to establish policies or issue directives respecting the manner in which clause 5 is to be applied. This essentially lays out the ability of the president to use policies to help departments in implementing the rule. Treasury Board policies are used frequently in government to guide departments in their operations. This sets out the ability of the minister to do that.

Clause 7 is the regulation-making authority under this bill. There are a couple of key components that authorities are given for the minister to make regulations to address. One is the manner of calculating the cost of administrative burden; the second is the period within which measures must be taken to comply with clause 5, the time in which a minister must reconcile a new in with a corresponding out. The way it has been operating in policy so far is that that period is 24 months. The minister has 24 months to make the reconciliation.

It also takes into account the fact that subclause (c) there allows for, in essence, the stocking of outs. So a minister can make a regulatory change that results in an out and allows him to take a credit for that out to apply to a future in. So that's what that essentially allows for.

Subclause (e) of clause 7 provides the ability for the exemption of particular regulations from the application of the rule — the so-called carve-outs. There are three currently under policy, and this clause will allow for the minister to set regulations about carve-outs under the bill.

Clause 8 is really to lay out the expectation that accountability for performance under this bill is really to be set out through public reporting and accountability through Parliament. In many respects it's a protection clause, but an important regulation — imagine a Food and Drugs Act regulation or an environmental or a rail safety regulation — cannot be rendered invalid because of a concern about how this act has been applied. We see this in other regulatory reform-type legislation, that you don't want important pieces of regulation to be rendered invalid because of something under this act, so it provides for that protection under clause 8.

Clause 9 is a requirement for the President of the Treasury Board to issue a public report by December 31 of each year and the government's implementation of the rule. To give senators a sense of what that would look like, right now under the application of the Red Tape Reduction Action Plan, an annual scorecard is prepared. That scorecard lists all the times the one-for-one rule has been applied, has tables and charts of all the different regulations where there have been carve-outs, where the rule has been applied, et cetera. That's what is envisioned by this, having that type of an annual report.

Clause 10 provides the regulation-making authority to lay out what must be included in that annual report. As I mentioned, those are the types of things that we should be thinking about — how is the rule applied, to what regulations is it applied? — so that there is an element of transparency in how the rule operates.

Clause 11 is a five-year review clause, a standard one that is seen in many pieces of legislation. It requires that the act be reviewed after five years.

That is the bill, in a nutshell.

The Chair: Thank you very much for that overview. Looking at clause 9, the President of the Treasury Board must prepare this annual scorecard. That would be a secretariat that has responsibility for that, and you are involved with that, Mr. Vandergrift?

Mr. Vandergrift: Yes, the secretariat supports the president in preparing this annual report, which would then be tabled, would be made public every year by December 31.

The Chair: Typically when we look at legislation we see the term "shall," and I see a "must" here instead of a "shall" in clause 9. Is there a reason for the "must" rather than "shall," and do you interpret that differently?

Mr. Vandergrift: I don't believe, Mr. Chair, that there will be any difference in interpretation there. The issue here is a compulsory, mandatory requirement to table the annual report. I'm not sure of any particular distinction in the word choice there.

The Chair: The sponsor of the bill, and we're very pleased to have him here with us, is Senator Black from Alberta.

Senator Black, do you have any comments, any questions that you would like to pose at this time as sponsor of the bill?

Senator Black: Thank you very much, Mr. Chair. I do not. I think the presentation has been succinct and thorough.

The Chair: If you have any intervention later on to help clarify some of the issues, we'll be pleased to call on you.

Senator Massicotte is the critic of the bill. He works not along with but close in the chamber to make sure that we understand the issues before we vote on them. Senator Massicotte is a senator from Montreal.


Senator Massicotte: I thank the witnesses for their appearance here today. I am critical of the bill, which means that it will be reviewed in depth. However, I fully support it. In principle, it deserves the support of both chambers, and it is important that the Senate give it sober second thought.

The objective of the bill is excellent, but the challenge is in its application in order to obtain results. There are no complexities in the bill, but since the 1970s, all governments have made empty promises about wanting to reduce red tape, even though they continue to produce reports showing developments on this issue. Despite everything, Canadians, and particularly Canadian businesses, still have doubts as to the results.

My question is therefore the following: this time, will it be different? We are using legislation, current methods and practices, in order to change the practices of officials and of legislators, but every time we pass a piece of legislation, we increase the tax burden, like an indirect tax. We believe this has no cost, but there are always costs, and our Canadian businesses become less competitive on a global scale. At the World Bank, there are several ways to rate businesses that show that Canadian businesses are more lucrative compared to those in other countries.

Are we going to be entitled to real results? Will we be able to say, 10 years from now, that we really have achieved progress? Twenty-two million dollars in one year's time will not be much compared to the machinery of government. Are we just beginning?


Mr. Albas: Thank you, and through you, Mr. Chair, I want to thank the senator and I appreciate the viewpoint you've taken, that you want to make sure you're doing your job to make sure we have the best legislation going forward.

Thank you for the support for the bill, and I want to take a step back, Mr. Chair.

I tabled a bill a few years ago, a private member's bill that received unanimous support. It was on eliminating interprovincial barriers for our wineries. So I take the point of the senator that sometimes it can seem to Canadian businesses that it's never-ending, but again we've shown before that when we all work together, we can eliminate these useless or ancient regulations in order to help Canadian businesses to prosper.

But getting back to the actual bill, this is a systematic approach the government has taken by working through the Treasury Board Secretariat specifically, restraining how regulators regulate, that they have to consider the administrative burden that would be on businesses, and then it also forces them, as daily operations move on, as new regulations come forward, to find savings in other areas. That modernizes our old stock of rules and makes them better.

I gave the example of hundreds of thousands of hours being saved, over $20 million in savings calculated. One particular one I would point out is great work by Employment and Social Development Canada. Their labour program reduced the red tape burden and cost to businesses by repealing a set of regulations that imposed unnecessary administrative requirements on construction companies awarded federal government contracts. With these savings, the estimated annual savings for those businesses in that red tape area is just shy of $1 million.

Employment and Social Development Canada has amended the Canadian Disability Savings Regulations, removing the 180-day requirement for Registered Disability Savings Plan grant and bond applications. Delays caused by this requirement created hardships for some of the beneficiaries, and its removal eliminates the need to resubmit applications. With these changes, the estimated annual savings for businesses is just shy of $400,000.

I know the government does share these concerns, and that's why the one-for-one rule bill is the cornerstone of our commitment to the follow-up to the Red Tape Reduction Action Plan of 2012. So I appreciate your comments. I appreciate your support, and I look forward to seeing more of those being reported as the scorecard presents that transparency.

Senator Massicotte: I know the act does not refer to and does not include the Income Tax Act per se, and it specifically does not include it. If you look at the polls of the business person, it's the number one irritant, if you wish; and since Mitchell Sharp, there have been no major revisions of the Income Tax Act since that time, and every year we add 10 or 15 pages to it. Could we get somewhat courageous? In the next five years, can we simplify that piece of legislation?

Mr. Albas: I appreciate your saying that. I know that Minister Findlay is from British Columbia. She's the Minister of National Revenue. I have been to two red tape reduction round tables with her, and specifically there are a number of initiatives that are being brought forward, irritants that don't make a lot of sense. CRA has done an excellent job of trying to deal with these issues as they come up. In fact, she actually was awarded the CFIB's Golden Scissors Award this past year for her work on reducing red tape.

This is something that we do take seriously, and I take your concern seriously because we want to see that businesses can interact with government to pay their fair share but also focus most on their businesses. I take your advice quite seriously.


Senator Bellemare: Thank you for being here today, sir. I also support this bill; I believe there is no problem with reducing the regulatory burden. My questions concern the scope of the bill.

At the National Finance Committee, we often meet with business representatives. During the study on the last budget implementation bill, concerning amendments that were made, for example, to the registration of trademarks — the legislator was abolishing the mandatory employment statement, the register and all of that — business representatives told us that this would entail huge costs for them. Today, we are faced with what is somewhat the opposite situation. We are not talking about a regulation, but indeed about internal deregulation that represents costs to businesses. Does this bill cover that kind of situation?


Mr. Albas: Thank you. I appreciate the senator's comments. We had the opportunity to work on a committee before, and you're very insightful on these things.

What I would go back to is, first of all, that there is a carve-out section, which Mr. Vandergrift mentioned. It has to do with our international obligations. Obviously, Canada does not exist on its own. We have to arm our small, medium-sized and larger businesses to be able to compete internationally; so joining with the international conventions, whether they happen to be trademarks or patents or whatnot, can bring that certainty so that our businesses know that when they decide to reach outside of our borders and create jobs at home, that there will be protections under the law.

Getting back to what we're here for today, the administrative burden, and what that means is not the compliance of it. So, for example, there is a rule on health and safety; they have to do those things. This is on how you should report to government. Should it always be where you have to fill out pieces of paper and send them to the government, and should that be monthly or once a year? Could it not be done through a single desk? Could it not be done through email?

So these are the things that the bill tries to do. It tries to get the regulators to look through the eyes of small business and see what makes sense and how to keep that administrative burden of any new rules as low as possible.

This particular bill focuses on that. Again, as Mr. Vandergrift mentioned earlier, it uses a standard cost model to be able to analyze how much a new regulation will cost as it goes in, as well as how much a revised regulation will be when they take it out. Hopefully that answers your question, at least on the international front.


Senator Bellemare: Yes, that answers my question and I thank you very much. The impacts of this bill have been studied since 2012. I imagine therefore that you have been able to calculate the costs. Could you elaborate a bit on how you would repeal one regulation of equal value and how you would calculate the costs of regulations that are the responsibility of businesses?


Mr. Albas: On this, the standard costing model I talked about before is used; it's an internationally accepted process. However, I do think it's important for all of us here to hear from someone who has to work with regulators on a regular basis. I'm going to ask Mr. Vandergrift to give us some details on that precisely because I think this is important for people to hear.

Mr. Vandergrift: Further, as the parliamentary secretary indicated, we use a standard cost model, and we provide a cost calculator to departments to help them work through the cost changes. When a department is making a regulatory change, what is new with the application of this rule is departments, for the first time, are having to account for the administrative burden cost of a regulation, to really understand what they are asking of regulated parties, of businesses to do and how much it costs them.

There are four elements: How long does it take you to do something, to meet the administrative burden? If we're asking you to fill out a form for a licence, how long does it take you to do that? What is the salary of the person doing it? How many people are doing it? You multiply that by the number of businesses across the economy that are doing it. Those four elements lead to a number which is then included in the regulation, and that is a number that's used to offset.

The same way when you're making a regulatory change, it reduces administrative burden. In the example that the parliamentary secretary gave with a low value of shipments, courier companies no longer have to submit a form for each shipment but rather can submit a form for a group of products when it's above the $2,500 threshold; and they cost how much it saves them to do that.

Departments are required to consult with the business in making these calculations, and they're also part of the Canada Gazette publication process as well, so that's also transparent in terms of the application of the rule as well.

The Chair: Mr. Vandergrift, the four-element test you've just described, were you defining the standard cost model?

Mr. Vandergrift: That's how the standard cost model is applied. Sorry, Mr. Chair, are we defining it in the bill?

The Chair: No. I just wanted to know if that was a standard cost model that you were describing to us.

Mr. Vandergrift: That's essentially the four elements of the model, yes.

The Chair: Are there other models that can be used?

Mr. Vandergrift: This is a model that's used by regulators. I think Holland was the first country to start using it, but it worked through the OECD comparative countries to try to capture — how do you capture the costs of the government regulation? It comes out of that work.


Senator Chaput: My questions follow on those asked by my colleagues. The first concerns the enforcement of this act, because we are talking about a major challenge in my opinion. Mr. Albas, could you give us some examples, even though I believe you have already provided us with a few? The one-for-one rule has already been in place for three years; how many cases have you already processed and how many do you expect to deal with in the years to come, perhaps annually?


Mr. Albas: Again, this is a system-wide approach. If a minister of the Crown puts forward a regulation that is not part of the health and safety carve-out, what ends up happening is that it goes through a process and the standard cost model is what is put forward.

As Mr. Vandergrift said, if the new in is larger than what they've taken out, they have up to 24 months to find another regulation that they could revise and find those savings elsewhere. At the end of the day, the cap or the one- for-one rule is honoured. There is some flexibility there to make sure Canadians' health and safety is never put at risk.

One of the great things, I think, senator, in regard to this piece of legislation is that it's very seldom that we actually get to vote on a piece of legislation that already has been tested and has already been found to have been beneficial to Canadian businesses.

You can rest assured that this process has been vetted, that the Government of Canada is going to be taking a word- leading position, because we'll be the first country in the world to put the one-for-one rule into law. I'd be happy to get you a copy of the annual scorecard so that you can look at some of the examples yourself and see the transparency that goes along with this. Not only is this a commitment to provide that certainty for businesses, that they know they have a partner in the Government of Canada that understands that we all have to work together to grow our economy and keep Canadians safe, but also we are looking at how we regulate and are attempting what the President of the Treasury Board refers to as a culture shift in the way Ottawa operates and regulates.


Senator Chaput: Could Mr. Albas perhaps send us the information?


The Chair: This is the scorecard?

Mr. Albas: It's a requirement, and I think we have copies that we can certainly distribute.

The Chair: Is it posted on the Treasury Board of Canada Secretariat website?

Mr. Vandergrift: Yes, it is.

The Chair: If you could provide one to us.

Mr. Vandergrift: We have extra copies.

The Chair: That's great, and we'll see that that sample is circulated, where we could go on an annual basis. When, annually, should we anticipate that the new scorecard would come out?

Mr. Vandergrift: December 31.


Senator Chaput: My second question concerns small businesses. On February 1, 2012, we approved the coming into force of the small business lens, and our small- and medium-sized businesses greatly appreciated this lens. However, why did you not include this in the bill?

Why, for example, does the bill not take into consideration the administration of income tax rules? This is a great concern to our small businesses. Why was an exception made for that?


Mr. Albas: That's a great question. As a former small-business owner, I ran my own business for 15 years, some of the best years of my life. I was happy to have done that because of all the benefits you have. One of the challenges you have is that not all businesses are small businesses. The small-business lens that you referred to is specifically to give regulators guidance on how the Government of Canada says, "If you are going to be implementing a new set of regulations, we want you to look at it through the eyes of a small business operator to make sure that it's practical, efficient and will not provide an overwhelming burden."

However, not all regulations apply just to small businesses. They may apply to a whole industry or sets of industries. The small-business lens will be applied particularly in the cases where a piece of regulation focuses and may actually harm small businesses. That's a view that we all, I think, as individuals always aspire to bring here, to bring a different view to Ottawa. This particular small-business lens is a valuable tool. It's a tool in the tool box in order for us to deal with red tape, but it may not apply in every case the same. That's why it is not included.

However, it is being actively used in many pieces of regulatory provisions.


Senator Chaput: However, do you recognize that in the opinion of small entrepreneurs, this lens would have been much stronger had it been included in the bill? Is that not correct?


Mr. Albas: I appreciate the viewpoint that we should for small businesses, but the small-business lens is basically for government to give insight into how it looks at regulating a particular problem. What we're doing by legislating the one-for-one rule into law is more restraining the government in how much administrative burden it can put forward. The small-business lens is a way of looking at the situation. Again, that's something that I think we, as parliamentarians, can be very proud of, that the government is changing not only the way in which it looks at small business but also the way it applies that knowledge through the one-for-one rule.

Senator Stewart Olsen: Thank you, gentlemen, for being with us today. I have two quick questions, and one is on the scorecard and how implementation is monitored. How do you that?

Mr. Albas: Thank you, senator. I appreciate that you have not had a chance to look at these, and we will be leaving copies and of course making the website available in case members want to refer to it later.

Basically there is a regulatory advisory committee that overviews the whole process. These are men and women from across the country, from various different disciplines, who lend their credibility to the process to make sure that this is not a government-talking-about-government process. It's people who are dealing with small business, dealing with all sorts of people every day. Basically the report itself goes right through how many regulations triggered the rule. In 2012-13, for example, there were 27; in 2013-14 there were 36. How many regulations were carved out, how many were only repealing other regulations. It goes through this all systematically.

It also points out, particularly from the regulatory advisory group's perspective, how well the government has kept its commitments in regard to this. It's important that we have a process we feel is sound and that also resonates outside of government.

Senator Stewart Olsen: Thank you. Dealing with an opposition claim that the one-for-one rule could endanger the health and safety of workers, I can't see how it could, but I wonder if you could elaborate on that for me.

Mr. Albas: Again, we're aiming for administrative burden. Administrative burden describes the effort required for Canadians or businesses to demonstrate compliance with federal regulations. That includes planning, collecting, processing and reporting information; completing forms; retaining data required by the federal government; filling out licence applications; finding and compiling data for audits; and learning about requirements.

We understand that all businesses have obligations, and regulators have to make sure there are firm rules in place that need to be followed. But we should always take a step back and ask ourselves if the way that we're asking for this information to be reported to government is on a regular basis and how best we should require that information to come forward. Again, the one-for-one rule has already proven to be very effective. The recent announcement, again, regarding small shipments for the courier companies will have a big cost savings, which hopefully will eventually be passed on to consumers. It's a competitive industry.

Senator Wallace: Mr. Vandergrift, you pointed out in the preamble, the third recital, that the one-for-one rule must not compromise public health, public safety and the Canadian economy, and some of my colleagues touched upon that. I take it that means that if a new regulation was developed that would impose a new administrative burden, a department would be justified in not implementing the one-for-one rule if it considered that it would compromise public health, public safety or the Canadian economy. Is that correct?

Mr. Vandergrift: The rule applies to all regulations. The way a carve-out works is that it can be applied by the Treasury Board should it feel it would have a challenge for health and safety. The experience to date has been that ministers have been able to bring forward regulations that have both ins and outs. This is about when ministers are designing regulations and to take account of the impact on administrative burden, to measure that, and to then offset it.

To date, ministers have been able to bring forward, and the rule works with both ins and outs. We've seen regulations that have ins and others that have outs. The balance has been to outs.

In terms of the way that would work, the minister brings forward regulation, and if there is a determination that the rule would have an impact on health and safety, it could be carved out. So that is available should there be an impact. But the experience to date is that the ministers have been bringing forward ins and outs in important areas of regulation.

Senator Wallace: In terms of the regulations in clause 7(e) where Treasury Board can enact regulations, I gather that would exempt circumstances in which the one-for-one rule would apply. Will there be regulations that provide more detail, that would support that third recital and actually describe the circumstances, or it would need to be demonstrated that if a one-for-one rule was applied it would or could compromise public health, safety or the Canadian economy?

For example, "would compromise the Canadian economy" is broad stuff. I don't know how you would define that.

Mr. Vandergrift: I should have mentioned that, senator. You are absolutely right. This will be described and laid out in that regulation. That's what that regulation authority is there for.

The Chair: Looking at clauses 6 and 7 that Senator Wallace was referring to, clause 7 gives the Governor-in-Council the authority to make regulations with respect to five different areas. So there is a whole new set of five different areas of regulations. And clause 6 of the bill states, "The President of the Treasury Board may establish policies or issue directives . . ." We're not trying to reduce the burden for lawyers here. It sounds to me like more will be developed.

Maybe I'm wrong on that, and perhaps you can help me. Is this just implementing policies that already exist under Treasury Board for the policy that has been in place for a couple of years now, and you have to move it into regulation because you're putting the other in law?

Mr. Albas: That's exactly it, Mr. Chair. This is simply because clause 7 basically allows the Governor-in-Council to make regulations on the following: It is how regulators are to calculate the red tape costs that Mr. Vandergrift mentioned earlier. There is also the time period in which regulators have to offset red tape costs, the ability to meet the requirement for the one-for-one rule, preserving the existing red tape cost surpluses and deficits, and the circumstances under which Treasury Board can exempt regulation. We're going from policy and now to law. Law therefore has to have its own regulations set up so that it can be administered.

Clause 6 states that "The President of the Treasury Board may establish policies or issue directives respecting the manner in which section 5 is to be applied." That goes back to the senator's earlier comments with regard to public health and safety to ensure that, just like any rule, there has to be an exception. This allows for that to be put into place.

Mr. Vandergrift: To give an example of a type of policy, there is a policy right now about how the rule is implemented. Regulations can be sponsored by two different ministers. We have to figure out to whom the credit or deficit is applied, to which portfolio. So we need to have a policy to make sure how that rule is applied in situations like that. This is an example of the policies and directives that are needed.

The Chair: But you have those policies now.

Mr. Vandergrift: There is a policy right now on how the rule is operationalized. You described it well in terms of how you move that into a legislative environment.

The Chair: The other question is why the government feels it is necessary to move from the existing regime, which you have described as being very successful, to putting it into a form of a law and regulations in policies.

Mr. Albas: First of all, I think it goes back to the Red Tape Reduction Action Plan commitments. The report was tabled in October 2012. It was identified right across the board by many stakeholders that this would provide certainty.

In my home province of British Columbia, the government implemented their own one-for-one rule, and it was very successful. This was also a Speech from the Throne commitment in 2013, so these are the things that government is doing to show two things. The first is leadership on the world stage, and that we're going to be the first jurisdiction to bring this in. Second, it sends that message of certainty to Canadian business that we have a government that listens and is looking to contain the overall administrative costs so that they can focus more on their businesses.

The Chair: You already did that in 2012, and we congratulate you for doing that. Now you're saying we had a policy that was working well, but now we want a law. What was the necessity for moving from the regime that was working well to this Bill C-21?

Mr. Albas: If it's in a Speech from the Throne, it's what the government intends to bring forward. But I think all of us, as parliamentarians, will be able to say when we go back to see our constituents and speak to people in our home provinces and territories that we heard it loud and clear, and we supported the Canadian government taking leadership on this front.

I understand the sentiment, and the one-for-one rule has been a very successful policy, but I also believe that by giving it debate in both houses and by having found support, it will show that we as parliamentarians are behind small business and want to see them succeed.

The Chair: I am correct that the policy has been in place and has been working for the last two years.

Mr. Albas: Yes, it's about two years.

The Chair: Maybe I misunderstood the process. It has been in place since 2012 as policy.

Mr. Albas: Yes, for almost three years as a policy.

The Chair: I will go to Senators Black and Massicotte to see if they have any wrap-up questions.

Senator Massicotte: I have two questions that are related. The proposed bill does not include laws or political decisions we make. It deals only with regulations. I fully support the bill, but why would you have that major exclusion? We can pass laws that increase the burden on business people, and that's not considered as a one-for-one.

Second, if you look at experience in the world, Singapore is a good example. If you look at the comments you got from the red tape committee, immense improvement can be made in the efficiency of the federal government by better using computers, the Internet, one form — one filing meets many satisfactions. That is not included, and there is no particular incentive to get there in this bill. Why is that excluded?

Mr. Albas: I'll start with your second question, and then we can address the first. I serve on the Public Accounts Committee for the House of Commons. The Auditor General did a review of the Government of Canada's efforts online and highlighted CRA as a very good example.

One of the concerns I raised specifically is that the Government of Canada has made many great efforts with Industry Canada, and CRA has done many good things online, and we will continue to encourage them to do that, but when we're seeking more access and convenience for Canadians, we also have to be mindful of privacy. If you do not have a completely 100 per cent trustworthy system, then that could compromise Canadians' privacy and Government of Canada information. That's one of the challenges you have. Again, each department is working diligently on these kinds of things to make better use of the Internet, but we also have to be mindful day by day, whether it be the hacks at Sony or Target where information about their consumers and their credit card information was given out, we cannot tolerate that kind of thing here.

To your earlier question about why it deals only with regulations, I sit on the Standing Joint Committee for the Scrutiny of Regulations. It's an excellent committee. Senator Hervieux-Payette is on that committee. It is one of the most thoughtful committees that I have been able to participate in. A big part of that is that we have our debates in both houses, and then we need to make sure that the regulations that come out, that regulators put forward, honour the spirit and the will of Parliament. That's why this particular bill also attempts to constrain individual regulators. It's not what they do — as parliamentarians, we tell them what they should do as far as law goes — but it's how they do it and how they regulate that I think is what's captured best in this piece of legislation, trying to reduce the administrative burden and to always keep an eye to make sure that the Government of Canada is not making it more difficult for small businesses to grow.

Senator Massicotte: If I can comment on the first point regarding the issue of privacy, I agree it's inexcusable if we don't cater to that, but that should not be an excuse for deficiency. Singapore is a very good example. They are extremely concerned with privacy, but they still achieve immense efficiency compared to our own government. I agree with that. Be honest. You've got to be honest.

Mr. Albas: Senator, I appreciate your comments, and I, too, agree. The Internet offers great opportunities for government, and I will continue to push for those.

Senator Black: Thank you very much, Mr. Chair, and thank you very much for your courtesy in running this hearing.

Thank you both as well for your very comprehensive presentation.

I have one observation and two questions, if I may. I think you know where I stand in respect of this legislation, so I think you will find the questions pretty manageable.

I think it's fair to say, and I indicated in my speech to the Senate, that this legislation is a good start. I don't think anyone would suggest this is the end of the regulatory reform agenda, but I've taken the position, and I would ask you to confirm or not that this is a very strong starting point for a Canadian business.

Based on that, I have two questions arising from the questions of my colleagues. I would like you to confirm whether or not you believe that enshrining the one-for-one principle into law with the attendant force of Parliament and the complexities involved in therefore amending the one-for-one law will signal a strong cultural change to the officials of government, more so than if we just stuck to regulation.

Mr. Albas: Absolutely. I think that this is something I have learned from listening to the President of the Treasury Board, because he's constantly talking about the need for a culture shift. We have disruptive technologies, we have greater expectations, and we have fantastic public servants right across this country working for Canadians. Again, those pressures that I pointed to always say that we need to improve constantly. A previous speaker pointed out that efficiencies needed to be found. There are so many different pressures on our public servants and regulators, but we should always expect the best of them, and I think the one-for-one rule is really about the government taking leadership on that, and that also involves our public servants being able to take a different view on how they regulate and to change with the times. I think this speaks more to that leadership position I mentioned earlier. It sends a signal out to the broader community that we're serious about growing small businesses, but it also talks about how we're serious about approaching how we operate here in Ottawa.

Senator Black: Is there anything you would like to add to that, Mr. Vandergrift?

Mr. Vandergrift: No.

Senator Black: My second question relates to a couple of excellent points that my colleagues raised regarding why this legislation does not apply to Canada Revenue Agency. We're going to hear testimony in the next hour from the Chartered Professional Accountants of Canada, and the testimony is now filed where they're asking the same question. They're commending government on this initiative, but they're wondering why we haven't gone further.

I did hear in your comments, parliamentary secretary, and I want to confirm that it's your testimony that the regulatory reduction is being addressed by Canada Revenue Agency.

Mr. Albas: Again, Minister Findlay has a great top-10 list of things they are doing to help reduce administrative burden on small businesses, such as increasing accountability — CRA, for example, giving out ID numbers for when you're talking to someone on the phone. If a small-business person has a question — let's say they have a tax decision they need to make — they can actually go on to their business account and ask questions of CRA and receive a written answer. If it turns out that they act on that information and that information was incorrect, it is honoured because it's on file as saying that that was their position.

It's not necessarily the whats. The whats have to be done. People have to pay their taxes, they have to pay their fair share, but it is the how. Again, by making it so that there is more accountability, having it so that more people can access more online information, these are the ways that CRA, for example, is doing that. What we're trying to do with the one-for-one rule is, like with my earlier mention of my private member's bill, rather than just identifying an issue of red tape and then doing a one-off, we are trying to work with Treasury Board Secretariat and all regulators to have a unified vision for how a new administrative burden has to be calculated. By that systematic approach, we're looking to see cost savings to business, which, especially in the more competitive sectors, will hopefully be passed on to the consumer. But again, it is a sea-change approach, that difference.

Senator Black: I assume that as that review is ongoing, Canada Revenue Agency will not be exempt from that review?

Mr. Albas: Again, the whole idea of the carve-outs is there for very good reasons. For example, Health Canada and Environment Canada both came as witnesses to the house committee that studied this bill, Government Operations, and they gave countless cases where they could show where their thinking and their approach have been changed, because Environment Canada and Health Canada put out a lot of regulations. They found this to be a very helpful process.

This is meant to be a cornerstone. It's not meant to be the only tool in the tool box, so to speak.

The Chair: Colleagues we have been studying this morning and will continue to study Bill C-21, An Act to control the administrative burden that regulations impose on businesses.

We thank Member of Parliament Dan Albas, Parliamentary Secretary to the President of the Treasury Board, for being here this morning and helping us understand the legislation. Mr. Vandergrift of the Treasury Board Secretariat, we thank you as well for being here.

Mr. Albas: I will be taking the feedback from your committee to the president as well.


The Chair: Honourable senators, we will continue our study of Bill C-21, An Act to control the administrative burden that regulations impose on businesses.


In our second hour this morning, we are pleased to welcome by video conference from Toronto, Mr. Gabe Hayos, Vice President of Taxation for the Chartered Professional Accountants of Canada, CPA.

Gabe Hayos, Vice President of Taxation, Chartered Professional Accountants of Canada: Mr. Chair, honourable senators, thank you for the opportunity to appear before you today to discuss Bill C-21, the red tape reduction act.

Chartered Professional Accountants of Canada, CPA Canada, is the national organization established to support a unified Canadian accounting profession. We represent Canada's CPAs and members of the three legacy designations — chartered accountants, certified management accountants and certified general accountants, all of which are unified or are unifying under the CPA banner. Once unification is complete, Canada's CPA designation will be more than 190,000 members strong.

For my comments today, I will provide some specific remarks on Bill C-21 and then address the issue of red tape reduction at a more general level.

CPA Canada generally supports Bill C-21, which places strict controls on the growth of regulatory red tape on business by enshrining the one-for-one rule. We understand that Canada is the first country in the world to legislate the one-for-one rule, and we applaud the government for championing this initiative.

While CPA Canada recognizes there are necessary and important regulations, we are keenly aware that excessive red tape places an undue burden on business and stifles growth, competitiveness and innovation. CPA Canada stands behind the federal government's action plan to reduce red tape.

CPA Canada believes that Bill C-21 will help control regulatory creep under the one-for-one rule; for every new regulation added, one must be removed. We are hopeful that this rule will put a lid on the cumulative regulatory burden, or regulatory creep, faced by Canadian businesses in their everyday commercial activities.

We also support the five-year parliamentary review clause in the legislation as it enforces discipline, accountability and transparency in the process.

However, one important concern that CPA Canada and other stakeholders have raised relates to the scope of the Red Tape Reduction Action Plan, of which the one-for-one rule is an element. The action plan is narrow in that it applies only to regulation, not to legislation or policy.

The one-for-one rule does not apply to new tax laws, nor does it consider the red tape burden and administrative costs that new tax laws impose on taxpayers, tax professionals and businesses. Under the Treasury Board's guide for the one-for-one rule, it is clearly written that "regulations related to tax or tax administration are carved out from the application of the rule."

Canada's complex tax system represents a significant administrative burden and cost to individual taxpayers and businesses. CPA Canada has raised a number of suggestions to reduce red tape, including modifying the T1135 foreign reporting form, simplifying the withholding requirements under regulations 102 and 105 of the Income Tax Act, and improving the T1/T3 filing process, which frankly has some elements that are broken.

CPA Canada is working with both Finance Canada and Canada Revenue Agency in these specific areas, with the intent of reducing red tape and irritants which impose an unnecessary burden and cost on Canadians.

CPA Canada would also encourage the government to look at other areas where it can make a meaningful difference and lessen the overall compliance burden for businesses and Canadians in general.

For example, we recommend that standardized business reporting, referred to namely as XBRL, be adopted for use by business for all government filings. This would reduce the compliance costs for business and improve the government's data collection, resulting in cost savings. The House of Commons Standing Committee on Finance included standardized business reporting in its pre-budget recommendations in both 2012 and 2013.

So thank you for your considerations, and I would be pleased to respond to any your questions.

The Chair: Thank you very much for your comments, and we've been provided with a written copy of your comments, which will be of assistance to each of the senators here.

Senator Hervieux-Payette: Thank you, Mr. Hayos. I still am wondering why we need a law to clean up our regulations. I feel that if I were the Prime Minister, tomorrow I would call my clerk, and I would say, "Sir, you appoint one person in each department and ask them to clean up the regulations, analyze the costs and recommend new regulations." I'm sitting on that committee, and of course we would be quite prepared to review.

In your opinion, how come this question has not been addressed? My colleague was saying in the last 50 years, in the last 25 years. How come we're just growing that beast?

I can see what is happening, for instance, at the provincial level with the medical form, which has cost so far over a billion dollars, and we don't have one yet to use. I'm just asking you as an accountant, somebody who is used to management practices, do you think in your organization that when you have new directives and so on, do you have to make such a big fuss? Do you study the problem, implement it and take a shortcut?

Mr. Hayos: I follow your point. I think I can comment on the income tax side, which is where I have experience. I will tell you that the Income Tax Act is very complicated. In order for the CRA to meet its mandate of collecting the revenue that's appropriate for it to collect, it is difficult and a challenge to do both the collection side and yet not overburden the taxpayer in trying to collect that tax. So there is a balance, and it's not easy to do. While it's easy to criticize it, it is a challenge.

Senator Hervieux-Payette: Is it not very useful for a profession like yours? The more lines we add to every income tax report, the more business you have.

Mr. Hayos: No. As professionals, it is not the best use of our time and effort for us to do things that are menial and cumbersome. We would prefer much more efficiency and do the things that we can contribute best, which is to provide appropriate advice to taxpayers.

Senator Hervieux-Payette: So you made representation to the government about the CRA, and I presume you were not heard, but do you have any confidence that this will be addressed in a short period of time?

Mr. Hayos: My comment is, first, I do think the government is listening, CRA is listening. We at CPA Canada have established a collaborative relationship with CRA with a view to dealing with a whole number of areas, of which red tape is one of the important ones. I think CRA is very committed to trying to reduce the red tape burden.

I listened a bit to the previous discussions, and I think what's clear is that the CRA has a number of stakeholders that it's considering, so it's a challenge. The fact that there is no oversight of the CRA, an independent oversight to question whether some of the regulatory burden is appropriate, balancing their obligations to collect revenue versus the requirements they put on taxpayers, is probably one of the concerns I have. Maybe there needs to be a bit of independent oversight, and the fact that there are exceptions in this red tape bill is one of the things that could be improved.

Senator Hervieux-Payette: Do you have a timeline in order to proceed with these amendments?

Mr. Hayos: No. The things that we've suggested are discussions. I think the three that I've highlighted in my presentation are very significant ones. We've had many discussions with the CRA, and we're hopeful that we'll see some changes in the short term. There already have been some in the foreign reporting, which is a very onerous reporting requirement. There have been some modifications. They just haven't been, in our view, sufficient to adequately deal with the burden that's been placed on taxpayers.

Senator Hervieux-Payette: Thank you.


Senator Bellemare: I would like to hear what your perspective is on the method of calculating the costs of a regulation. Do you agree with the choice made by the government? Given your expertise as an accountant, in your opinion, is the method used by the OECD to calculate the costs of a regulation the right one?


Mr. Hayos: Unfortunately that's something I have not addressed and don't think I could comment on.


Senator Bellemare: That is unfortunate.

The Chair: Thank you nevertheless.


Senator Massicotte: Thank you very much for being with us. You said you listened to our discussion with the parliamentary secretary and the assistant secretary earlier. Am I correct in saying that?

Mr. Hayos: I only heard the last 10 minutes, unfortunately. I wasn't linked in before.

Senator Massicotte: Basically in your presentation today you make two points of value. You commented that unfortunately this legislation does not apply to the Income Tax Act, and you thought it should. The other comment you made is that it does not apply to the laws but only to regulations. Relative to the first you said basically, yes, it is excluded; we're making good progress, but it's too complicated to include it, regarding the laws and so on. You obviously said parliamentarians should have full freedom and should not be limited by this act. That is basically my summary, and maybe you would disagree with that.

What's your response to that? Are you satisfied with that response?

Mr. Hayos: I think the Income Tax Act is very complicated, and to put in simply a mechanical rule that requires change without considering the impact, you can't just do a mechanical calculation and solve the problems with the Income Tax Act.

I do think some independent oversight is needed so that there's a challenge if there's administrative burden, the cost of the burden versus the revenue that's being raised would be a useful way to deal with issues that arise under the Income Tax Act. I think the issue is when the government itself is the one determining whether the balance is correct. Then you're never certain that you have the right balance.

Senator Massicotte: You also are aware, I'm sure, that this practice, the one-for-one, along with another program, including the small-business lens, has been in place for the last couple of years. In fact an annual report is published that is a scorecard-type of process. Have you had a chance to take a look at that? Are you satisfied with the progress we're achieving from this whole concept?

Mr. Hayos: I can only comment on it from the perspective of what I know the CRA has done. There is no doubt in my mind that the CRA takes this extremely seriously, from the minister down. I can tell you that from my personal experience.

Whether I'm always satisfied with the results, I wouldn't say that I am, but I also recognize that the CRA has many challenges in doing things. I can tell you that this is important to the CRA, and that has been my experience over the last number of years.

Senator Massicotte: If you look at the last report card, they've calculated that, given the new regulation, they've suppressed $22 million of burden, if you wish, from that process. Is that a good number? Is that enough? Is that significant?

Mr. Hayos: I'm really not in a position to comment on that.

The Chair: Mr. Hayos, you indicated in your comments that the action plan is narrow in that it applies only to regulations and not to legislation or policy, but in effect it applies only to certain regulations and not all. It's even narrower than your comment. As I read one of the sections, the regulations talk about a burden, an administrative burden. It has to impose a new administrative burden or remove an administrative burden, which is different from regulations generally. Clause 7 provides the authority of the Governor-in-Council, as a result of this legislation, to make significant new regulations.

There are five different categories, but the first one is the manner of calculating the cost of the administrative burden, et cetera.

I would assume that these regulations would be regulations that, as an accountant, you and your colleagues would be spending a lot of time looking at.

Mr. Hayos: Certainly that is something we could look at. I have not, at this stage, been looking at that in detail, and it's something that we might well do. As I said, my focus has been on the income tax area, and that has been largely excluded from this.

The Chair: I understand your point. I was, in effect, confirming your point that this legislation is quite narrow and relates only to certain regulations and not all. In fact, it invites the creation of more regulations.

Mr. Hayos: Absolutely. I'm not sure that the creation of new regulations is, by itself, a bad thing, as long as it's balanced with the administrative burden that's imposed as a result of it. The regulations are typically for a valid reason.

The Chair: Thank you for that, and I appreciate your help.

Senator L. Smith: Good morning. I just wanted to follow up on the question on oversight.

What type of thought have you had a chance to give to that, and if you could just develop your idea a little more in terms of giving us feedback, I think it might be helpful.

Mr. Hayos: What CPA Canada, as an example, has actually proposed, and the House of Commons standing committee has supported, is some process for tax simplification, and we actually suggested a two-part approach to this.

The first part is sort of what you would perhaps call an office of tax simplification. There are models around the world. The U.K. has an example. The idea is if there are new regulations or legislation, or existing ones that are not working, an independent office of tax simplification would be there to challenge and oversee whether there is a balance between the concerns about revenue and the burden on the tax system. So that's one suggestion.

In a broader sense, we propose that perhaps an expert panel would look at the whole tax system with a view to seeing if there are systemic problems that can be changed. Remember that this tax system has been a layer of new rules and regulations year after year, and there's a point at which you need to review this; and since the Carter commission back in the late 1960s, there hasn't been any major review.

We felt that with this two-stage approach you could look at low-hanging fruit, problems that exist today, and with the expert panel look to a longer-term solution to some of the issues on the tax system. Without the government's commitment to something like that, I don't think you can make substantial changes to ease the burden on taxpayers.

The Chair: I'm just new to this legislation, Mr. Hayos, so I may be overlooking this, but I can't see where the legislation excludes regulations that impose an administrative burden in relation to tax measures, where that is excluded. That presumably is in the policy and the regulations but not in the legislation. Am I correct in that?

Mr. Hayos: Unfortunately, I don't have the clause in front of me, but I think there is a specific carve-out within the act.

The Chair: If Senator Black or Senator Massicotte can help us on that, I would appreciate it.

I guess the point I'm making is that if we're passing this legislation in a broader sense than has been applied through policy and they continue to have the carve-out in regulation, that situation can be much more easily changed than legislation.

Senator Massicotte will help us.

Senator Massicotte: If you look at the definitions under paragraph 2, they define "regulation." As you know, the rest of the act deals with the word "regulation." And the regulation is specifically defined under section 2(1) of the Statutory Instruments Act.

Senator Black: My understanding is that your position is correct, but I will confirm that. I don't have that data now.

The Chair: If you could let us know, because the point has been made by the Chartered Public Accountants, and if we could find out what might have to be done to look at that in the future, that would be helpful.

Senator Black: Yes. Thank you.

Mr. Hayos: We'll also come back with our comments.

The Chair: Thank you very much, Mr. Hayos.

Is there anything further of Senator Massicotte or Senator Black?

Senator Black: I would just like to thank Mr. Hayos for his very strong contribution. I thought that your comments, although not specifically related to the bill, around oversight were also helpful on a go-forward basis, so thank you very much for that.

Mr. Hayos: Thank you.

Senator Massicotte: You work for a very large accounting firm. Am I correct in saying that?

Mr. Hayos: No. I work for the organization. I used to work for a large accounting firm. I now work for CPA Canada, which oversees all the accountants.

Senator Massicotte: Given your experience or background, a very important issue for us is the international standard accounting concept that the model refers to, and it's actually been used around the world by many firms, never as a law but always a policy. Could you get any comment from your branches in the Netherlands or someplace saying how the model is working, what the failure may be, if it is the right reference point? I know it's an OECD reference point, but any comments you can get from your associates on that model would be much appreciated.

Mr. Hayos: Okay, that's a point that we'll take forward.

Senator Wallace: I was listening to your comments in particular, chair, about the breadth of the bill and that there is always room, that we could be broader and do more, and over time I'm sure that will happen. As Mr. Hayos pointed out, this is a very important first step.

I just wanted to come back to Mr. Hayos's comments in his presentation to remind each of us, and the viewers, that, as he points out, Canada is the first country in the world to legislate the one-for-one rule. So, yes, there's always room to go and improvements to be made, but I thank you for pointing that out, sir. I think that is very important.

Mr. Hayos: Yes. I concur with that. The fact that the government has been out there publicly making its case for approving reducing red tape and then being prepared to put it into a legislative form is a first, good step. Sometimes these things have to work incrementally so that you see what you have and what you're missing. I agree.

The Chair: My final comment, Mr. Hayos, is congratulations to you on the accountants breaking down provincial barriers and creating this umbrella organization of which you're Vice President of Taxation for the Chartered Professional Accountants of Canada.

Mr. Hayos: Yes, I certainly wasn't a huge player; so many people across Canada were involved. I don't know that everybody appreciates the fact that this also is a first in the world that any place has got all three accounting bodies to come together and be collaborative and work as one organization. To me it's a huge accomplishment, and hopefully it will be in the best interests of the public.

The Chair: It's nice to know some of those barriers have been removed, and we appreciate you taking the time to be with us today.

Mr. Hayos: Thank you for the comments.

The Chair: Colleagues, that concludes today's session. Before we adjourn, I will tell you that we're planning to have further hearings tomorrow evening. If there is any witness you would like to hear, please let one of us in steering or the clerk know. We have space tomorrow, but we're intending to conclude the hearings on this tomorrow evening.


Senator Hervieux-Payette: I would like to know if the Canadian Federation of Independent Business is one of the witnesses.

The Chair: Tomorrow night.


Then the intention is to proceed with clause by clause. It would be disrespectful to proceed immediately following our witnesses, but it will be within a reasonable period of time following that. We're looking at this room on Thursday morning for clause by clause.

Senator Massicotte: Is the chamber of commerce one of our witnesses? They should appreciate the report on the efficiency of the government and things we should concentrate on.

The Chair: The Canadian Chamber of Commerce is based here in Ottawa. We will see if there is somebody on short notice who could come and help us. That's helpful. Thank you.

If there is nothing further, then this concludes this meeting. Thank you.

(The committee adjourned.)