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POFO - Standing Committee

Fisheries and Oceans

 

Proceedings of the Standing Senate Committee on 
Fisheries and Oceans

Issue 15 - Evidence


OTTAWA, Tuesday, November 25, 2014

The Standing Senate Committee on Fisheries and Oceans met this day at 5:55 p.m. to examine Fisheries and Oceans Canada's Proposal to Parliament for User Fees and Service Standards for Aquaculture Licenses under the Pacific Aquaculture Regulations, dated September 25, 2014, pursuant to the User Fees Act, S.C. 2004, c. 6, sbs. 4(2).

Senator Fabian Manning (Chair) in the chair.

[English]

The Chair: I'm pleased to welcome each and every one of you to this meeting of the Standing Senate Committee on Fisheries and Oceans. My name is Fabian Manning. I'm a senator from Newfoundland and Labrador and I am chair of this committee. Before I invite our witnesses to speak, I would like to invite the members of the committee to introduce themselves.

Senator Meredith: Senator Meredith, Ontario.

Senator Tkachuk: Senator Tkachuk, Saskatchewan.

Senator McInnis: Senator McInnis, Nova Scotia.

Senator Poirier: Senator Poirier, New Brunswick.

Senator Stewart Olsen: Carolyn Stewart Olsen, New Brunswick.

Senator Raine: Nancy Greene Raine from British Columbia.

The Chair: Thank you, senators. We may have another senator joining us later.

The committee is beginning its study of Fisheries and Oceans Canada's proposal to Parliament for user fees and service standards for aquaculture licences under the Pacific Aquaculture Regulations. The proposal was deemed referred to the committee by the Senate on Wednesday, October 1, 2014, pursuant to rule 12-8(2).

We are pleased to welcome senior officials from the Department of Fisheries and Oceans Canada. I would ask them to introduce themselves before we begin.

Kevin Stringer, Senior Assistant Deputy Minister, Ecosystems and Fisheries Management, Fisheries and Oceans Canada: Thank you very much. My name is Kevin Stringer. I'm the Assistant Deputy Minister for Ecosystems and Fisheries Management. We have short opening remarks, but I will first ask my colleagues to introduce themselves.

Jay Parsons, Director, Aquaculture Science, Fisheries and Oceans Canada: Jay Parsons, director of aquaculture biotechnology and aquatic animal health sciences with Fisheries and Oceans.

Eric Gilbert, Director General, Aquaculture Operations, Ecosystems and Aquaculture Management, Fisheries and Oceans Canada: Eric Gilbert, director general of aquaculture management with DFO here in Ottawa.

Alistair Struthers, Director, Aquaculture Operations, Fisheries and Oceans Canada: Alistair Struthers, Director, Aquaculture Operations with the aquaculture management directorate.

The Chair: Thank you very much.

The senator who just arrived, would you let us know who you are?

Senator Munson: Senator Jim Munson, I'm an Ontario senator but my heart is in New Brunswick. I'm here for 30 minutes today.

The Chair: Thanks for giving us notice.

On behalf of the members of the committee, I thank you for being here today. I understand, Mr. Stringer, you have some brief opening remarks you'd like to make, and then we'll have questions from senators. The floor is yours.

Mr. Stringer: Thank you very much for the invitation. It really is a pleasure for us to be here to provide some context and answer questions on the proposal for B.C. aquaculture licence fees.

I'll speak a little bit about the process that we've been through, how we've come up with the proposal that is before you and then make a few comments, although you already have information, on the fees themselves, the principles and what the fees entail.

[Translation]

As you are no doubt aware based on your current study, the global demand for fish and seafood continues to rise. While traditional wild capture fisheries may supply part of this increasing demand, aquaculture production will be its main source. On account of Canada's vast and rich aquatic resources, we have tremendous potential to become a major contributor to this global demand. This is an opportunity to help revitalize coastal, rural, and aboriginal communities by providing important jobs.

[English]

We are committed to ensure that any such growth takes place in a sustainable way while maintaining a strong and modern regulatory regime that protects the environment. As part of the department's regulatory reform agenda, these proposed licence fees are designed to help assure Canadians that those who access our natural resources for private gain pay an appropriate fee and are accountable to appropriate regulatory standards.

As a bit about how we got here, in 2009 the B.C. Supreme Court ruled that the management of aquaculture in the province of B.C. falls under federal jurisdiction, and it gave the federal government until December 2010 — four years ago from now — to establish a new regulatory regime and a program to operate aquaculture in B.C. As a result, the federal government developed the Pacific Aquaculture Regulations under the Fisheries Act. Those regulations came into effect on December 18, 2010, when the department officially assumed regulatory authority. Among other things, they allow the minister to issue licences and to set conditions on those licences.

While this work was under way, DFO committed to establishing licence fees as well, which would be fair and simple to administer and understand. The requirement to undertake the User Fees Act process, however, meant that it was impossible to implement these fees at the same time the regulatory regime came into effect.

Once the regulation was in place at the end of 2010, in 2011 we started work on the licence fee regime. We conducted initial internal analysis for potential licence fees, reviewed the previous regime, looked at charges by other jurisdictions in Canada and elsewhere, and we looked at different models.

In the spring of 2012, the department held a set of preliminary meetings with targeted stakeholders and First Nations to consider all of this. We also solicited input for other elements we might have missed or concerns others might have. We received useful feedback in these discussions and developed an approach which is the foundation for the proposal before you.

In fall of last year, DFO prepared a discussion document, initiated a 30-day public comment period and undertook a mail-out of 591 discussion packages to all B.C. licence holders and to First Nations, with directions on how to participate. A notice of intent to consult was also published in Canada Gazette, Part I, to ensure that the 30-day comment period was open to all Canadians. So we've had significant opportunity for input and we've received significant input. We had a dedicated website where we provided background, discussion materials, links to other relevant documents and information on how to provide input.

[Translation]

At the conclusion of the comment period, 607 visits to the website were registered and a total of 113 comments were received. The majority, 84, were in favour of the proposed fees. Of those opposed, 15 were concerned that the proposed fee is too low. DFO responded to comments where necessary and encouraged participants to continue the dialogue.

Following this stage, the User Fees Act process provides for another 30-day period where formal complaints could be submitted. However, no complaints were received related to the proposed fees and the final part of the complaint process, an independent advisory panel, was not required.

[English]

So with that process in place, we pulled together all the input we had received and developed the final proposal, which was tabled in Parliament for consideration earlier this year and referred to this committee for review.

Following this review you're undertaking, and consideration of any recommendations put forward, the department would continue to finalize the regulatory amendment process.

I have a few quick points on the fees themselves. The fee proposal before you outlines some of the principles and objectives that we've tried to look at and be faithful to. I'll just outline a few of them.

We've been guided by a set of core principles and objectives. The fees should be simple, fair and easy to understand for licence holders and easy to apply. The fees should take into account practical matters of factors such as allowable production volume, size of operation, differences between finfish and shellfish, and freshwater land-based operations. The fees should address cost recovery and the privilege to access a public resource. The fees should not impact competitiveness. They should not be out of line with previous fees or fees charged in other jurisdictions in Canada and internationally.

At the end of the day, we are proposing a fee comprised of two components: one, a flat fee applied to partially recover administrative costs; and, two, an access-to-resource fee for exclusive use of a federally regulated resource. The flat fee would apply to all licence holders. However, for the resource-based portion of the fee, finfish growers would pay a fee based on the maximum amount of fish they're licensed to produce, measured in tonnage. Shellfish growers would pay a fee based on the amount of area used, measured in hectares. Since freshwater and land-based operations do not have privileged access to a federally regulated resource, they would only pay the flat fee. Furthermore, enhancement facilities would not pay any licence fees as they don't derive a private economic benefit for the use of a public resource.

I have two final points. First, note that in terms of the fees that B.C. licence holders or facilities pay, the licence is only one piece that they pay. The province has maintained responsibility for issuing aquaculture leases or tenures on the lands under their jurisdiction, and they collect fees related to this. This amounts to approximately $1.5 million a year, and that is more substantive at the end of the day than what the licence fees will be.

Second, we have consulted broadly. Industry has maintained general support for the implementation of fees and expressed these sentiments throughout the consultative process. They have indicated that they're interested in having fees issued for a longer period of time rather than issued annually. It could be three years, six years. To this end, they've asked us to adjust the regulation to enable fees to be paid in installments. Right now, we can already provide licences for a longer period of time, but you have to pay the fee up front. If we can do annual installments, that's a small regulatory change. We could move in the direction of multi-year aquaculture licences in B.C. and the department would be generally supportive of this as well.

In summary, the user fee process has been extensive. It has been inclusive, challenging and a long process. But it's been a very useful process that has allowed us to develop a proposed fee regime that we believe does meet the objectives and principles we're trying to achieve. It is, we hope, reasonably simple, fair and easy to understand and apply, and we think it will work.

We're pleased to answer any questions, hear your views and very much look forward to your final report.

The Chair: Thank you very much, Mr. Stringer. It's certainly a detailed summary of events thus far. I'm going to ask Senator Raine to lead off our questions this evening.

Senator Raine: Thank you very much. It's good to hear the background on the process, how long it was and how thorough it was. That gives us all a little bit of comfort.

I have a question about the 2 per cent annual adjustment mechanism. I'm questioning why you took a flat 2 per cent. I sit on the Aboriginal People's Committee and some things have been capped at 2 per cent, which is causing all kinds of problems. If inflation is above 2 per cent, does it make sense to cap it at 2 per cent? Should it not be capped to inflation rather than set at a percentage?

Mr. Stringer: With regard to the issue of putting something in there to allow it to change, the challenge that we've gone through, the extensive process on this regulation, has been huge. The idea that in three or four years you would want to go and do that again to adjust it is the challenge. We did come up with the concept that there needs to be some self-adjustment.

The question is an excellent one. How do you come up with a reasonable number? Do you link it to inflation? We've been told that that's generally not done, linking it to inflation, but I believe this is an explanation of inflation over the last X number of years with a reasonable estimate that that would be what is in place going forward. That's basically it, but I will ask Eric or Alistair to speak to it.

Mr. Gilbert: Actually, it's a very good question because it's one of the few that we struggled with for a long time. Kevin provided part of the answer.

The other part of that is the fact that we've been advised by the central agency that a good way to deal with the increasing cost of fees is also to look at the Bank of Canada target inflation rate. As you know, the Bank of Canada is trying to put measures in place in order to maintain the inflation rate at a given number, and 2 per cent is the number they've been targeting for a long time and they will target over the next few years.

The other option would have been to look at the price index, which is not easy. We mentioned that one of the principles that guides our work in order to end up with this proposal in front of you is that we have to keep it simple and we have to make sure it will be easy to manage. The 2 per cent was at the end of this thinking process. It's not perfect. It's not the ideal scenario, but it's the best that we can achieve.

Nobody would wish this, but like we did in the 1980s, if Canada entered into a period where the inflation rate would be maintained at the highest level for years, we could always go back to the central agency and amend that regulation to change that rate if there is a need. It's not set in stone forever. This is a regulation that could be amended down the road if need be.

Senator Raine: Could you explain what you mean by ''central agency''?

Mr. Gilbert: Treasury Board.

Senator Raine: And you say that's not generally done?

Mr. Gilbert: Using the price index. That is taking care of inflation, maybe not on a daily basis, but it's published on a yearly basis for sure. In a regulation, it's difficult to reference an index that is not under our control.

Alistair, do you want to add a few things?

Mr. Struthers: As Eric pointed out, it was a concept that we struggled with a fair amount. Two per cent is the targeted inflation rate set by the Bank of Canada. The average inflation rate for the last 15 years has been 1.89 per cent, so we're in line with that. It's not perfect, but it is simple and easy to understand.

As Eric mentioned on the consumer price index, that would be the most accurate way of having it adjusted based on the consumer price index each year. It's an idea that, in theory, most people kind of get. It's linked to inflation. However, the actual ability to calculate it is a question of the basket of goods you use, the time of year. We would then have to publish this on DFO's website. We've also been advised by lawyers in the drafting process that if we have a formula within our regulations that requires the fee payer to look outside of the regulations, it might become a little problematic from a transparency perspective.

Senator Munson: I know we're here to talk about the User Fees Act, but you folks have been involved so much in the aquaculture industry, and I think we all want to have a more vibrant aquaculture industry. We've been across the country listening to a great amount of testimony about too much regulation and too many departments, and the whole idea is that most in the industry would like to have an aquaculture act.

It seems to be in a frozen state with no growth. When you go on a journey to Scotland and Norway and see the immensity of the work being done there, and the way things are marketed here from other countries, Canada has such great potential.

You folks have been around for some time. Could I get your view of where we're at now within the industry from the point of view of a bureaucratic process? You play a fundamental role with this.

In fishing, the aquaculture industry, they call themselves fish farmers, for example. They feel more comfortable with the farming industry as opposed to the fishery, per se. I would like to get an overview of your views of where we're at now, because we need your input as well before we put this report out.

The Chair: Just as a point, senator, as you began your statement you realize our witnesses are here to discuss user fees. If, for any reason or another, you don't want to delve into that, we can have that at another time. If you want to, the door is open, but we're here to discuss user fees.

I'll leave it to your discretion, Mr. Stringer.

Mr. Stringer: Thank you. I'll quickly respond. I also note that I think we're due back here next week on the aquaculture activity regulation, which is closer to the broader regulatory topic.

A number of us spent the day with CAIA, the Canadian Aquaculture Industry Alliance. They had their annual general meeting today in Ottawa, and I appeared before them with Eric and a couple of colleagues, and then Science did a presentation this afternoon; so we work very closely with the industry. I will tell you what I said in terms of where things are at. I will just reflect on it.

Number one, 50 per cent of the world's fish resources now come from aquaculture and that is up enormously from before. The world will need fish resources for protein. There are formal estimates from the UN and the FAO about how much will be needed and how much we have as a deficit.

My job as a fish manager is to make sure that as much of that as possible comes from the wild fishery. I don't know that anybody in the world thinks we will have a doubling of the wild fishery over the next 30 years. A substantial portion of that needs to come from aquaculture, and Canada is well positioned. Our job at DFO and in the Government of Canada is to make sure that that growth is enabled with strong, environmentally responsible regulation.

The regulations we will be talking about next week, the Aquaculture Activities Regulations, are part of that. I would say that PAR, the Pacific Aquaculture Regulations which we passed in 2010 that we're doing fees for today and talking about today, and that the committee is considering now, is another piece of that, but there are other elements of those. We'd be happy to talk about those things.

It is a challenge, but that is our objective and discussions with the industries are ongoing.

The Chair: Thank you, Mr. Stringer. We certainly look forward to you elaborating on some of those facts next week or in the future.

Are you finished, Senator Munson?

Senator Munson: Well, I guess I am.

The Chair: You are now.

Senator Munson: The user fees are not as exciting as the other stuff. I understand user fees, but I'll come back next week and we can get into the whole play that's out there. I truly believe, as we've seen, chair, that there are challenges, but there has to be change with those challenges.

The Chair: Stay tuned.

Senator Meredith: Mr. Stringer, thank you for your presentation. You talked about the consultation process. As a former member of the Aboriginal Committee, we're consistently going back to duty to consult and treaty rights and so forth. You talked about the opportunity to grow this industry, and we see there are great potentials. My colleague has mentioned some of the trips we have just been on and see Canada lagging behind. One of my concerns is to ensure that the First Nations people of Canada are truly engaged in the aquaculture industry and that they become participants.

My question to you is with respect to the consultation process. What were some of the steps taken? Can you certify to the committee today that you have exhausted those processes? What were the results of those processes with respect to commitments from the First Nations people to agree to these fees?

When I see these things, I don't want us to come back around to another round of discussions on this matter or find there's some opposition to it. I'd like to be clear that we've done everything we can. If you don't mind elaborating for me on that process, I then will have a final question for you.

Mr. Stringer: I will start and then ask Eric to add to this because he was at some of the meetings with First Nations.

I talked in my opening remarks about a pretty extensive process we had, partly because we thought it was a good idea, partly because we have responsibilities for First Nations, but also because the User Fees Act is basically a pretty prescriptive process that requires this type of engagement.

In terms of First Nations, I'd say there were three or four entry points. In our first considerations, we had discussions with the B.C. First Nations Fisheries Council around the fees and what we were doing. When the discussion paper went out in the fall of 2013, the materials were sent to all 203 First Nations in British Columbia. So there were at least those two pieces.

We have also identified in a process with the First Nations Leadership Council and the First Nations Fisheries Council, which supports the First Nations Leadership Council in B.C., that aquaculture is an item to discuss, so we have a number of issues that we discuss with First Nations, licence fees being one piece of that. It was a pretty extensive process in that regard.

I'll ask Eric if there's anything specific that we have heard from First Nations. As you point out, aquaculture is a big issue in B.C.

Mr. Gilbert: Very briefly, you described the process properly. One thing we need to mention is that we sent out the consultation package to all First Nations, which included a letter explaining what this was all about, a discussion document elaborating on options, and so on. We invited First Nations to get back to us with specific comments and views on it in order for us to take that into consideration. At the same time, we organized specific meetings to explain what this was all about and heard a review about it.

I have to say, though, that we didn't receive any written First Nation comments through the mail-out process. Even with that, we know in some cases it's not always easy for First Nations to participate in all those consultation processes we're tabling in front of them as a government, both at the provincial and federal levels. We didn't take it as a fact that they didn't have anything to say.

After the mail-out, we organized a meeting. In terms of summarizing what we had heard, in B.C. there are some First Nations totally opposed to aquaculture, and we have the whole spectrum. On the other side we have First Nations already engaged in aquaculture, and we even have First Nations now submitting aquaculture licence applications in order to really master the business, sometimes in joint venture with the private industry and sometimes all by themselves.

The main thing we heard was not so much that they were against the fee itself, but they asked for some consideration of options where we could redistribute the fees we were collecting to address some of their needs. Unfortunately, we don't have any legal mechanism to put the money aside and take it back to fund some specific First Nation program.

However, that being said, we do have other programs that are very active in helping First Nations communities that are interested in being part of the aquaculture business. As an example, just recently, in partnership with AANDC, we developed what we call the Aboriginal Aquaculture in Canada Initiative. That program is managed by us with funds coming from AANDC; up to over three years we are spending $4 million. That program is out there to help First Nations that want to develop a business case and start to be involved in aquaculture, to get the tools they need to do that.

Some First Nations organizations, like the B.C. First Nations Fisheries Council, the Aboriginal Aquaculture Association, which is also in B.C., received money to hire technical experts who could provide expertise to specific First Nations that want to get involved in aquaculture.

Senator Meredith: So 203 First Nations, packages were sent out, no written confirmation was received, and then you had a meeting. How many of those First Nations showed up at that meeting that you can recall?

Mr. Gilbert: I'll ask Alistair to confirm, but I do remember meeting in Nanaimo, organized by the Aboriginal Aquaculture Association, where we had close to 30 First Nations represented, but that association has a membership of First Nations who already are or want to be involved in aquaculture. That creates a lot more interest than meetings that we organize with, for instance, the B.C. First Nations Fisheries Council where all views were presented to us, pros and against aquaculture.

Mr. Struthers: The meeting Eric is referring to was actually the first meeting we had on the licence fees, and the response we got from the First Nations was, ''Well, you're coming to us at which point in the process?'' We informed them it was actually the beginning of the process. They were very pleased and said it was the first time they'd been engaged at the very beginning.

There were about 25 to 30 representatives from various coastal First Nations. Obviously the coastal First Nations are the ones that have a direct interest in aquaculture.

Senator Meredith: So 25 to 30 showed up out of the 203 First Nations you had given notices to. From that you ascertained that you had enough information to proceed with the process. Is that what I'm hearing, Mr. Stringer?

Mr. Gilbert: Just a caveat here. We did provide all First Nations with all the information we could think of that would be useful for them to look at the issue, look at the proposal we have and provide us with their views on it. The meeting we organized after was not to close the file. When I said we didn't receive any written comments, I meant that even though we provided all First Nations with this information — we had the discussion document, links to websites, a phone number to call in order to discuss further — all sent specifically in order to ensure that First Nations would be engaged properly and have everything they needed in order to get back to us, we didn't receive any written comments. It's not unusual in the world of First Nations consultation.

The point I want to make is that after that step we didn't talk about it internally by saying, ''That's fine; we did consult and we didn't receive anything back from them so it's a done deal.'' We didn't build the development of the proposal on that premise. We organized other meetings to make sure that even in person we could share the initiative with those who had shown up at the meeting.

Senator Meredith: I just want clarity on that process so there's no coming back or challenges that the department might face going forward. In terms of clarity, I want to make sure it's on the record that you've followed the process and have tried to engage as best as possible to get both their written and verbal consent to these fees.

My last and final question is on the fact that you mentioned that 113 comments were made on your website, and 84 of those were in favour. The others, you said, were in favour or there was a split in terms of the —

Mr. Stringer: There were 15, I think, that expressed concern. The 15 basically said they thought the fees were too low and we should be charging something higher.

Senator Meredith: Just a general comment?

Mr. Stringer: Yes.

Senator Meredith: Was any rationale given?

Mr. Stringer: I don't know, Alistair, if you know the specifics, or either of you?

Mr. Gilbert: The main ones we received complaining that the fees were not high enough were coming from environmental organizations. One of their main comments was that the environmental impact, in their view, of the industry was not factored into the cost for using that resource that they are having an impact on, i.e., the marine environment.

Our answer to that was the fact that the fees are not the right tool to use in order to make sure that those externalities are taken into account. The regulatory regime as a whole does that through the licensing process and through all the conditions that we're attaching to any licence in order to make sure that the risk to the environment is at the lowest level possible. Therefore, all those conditions that we're imposing on the industry do have some cost related to them. They have to do stuff related to those conditions. They have to develop a fish management plan. They have to monitor their impact on a regular basis and provide that information to us, and on and on. Here is where we're doing the so-called externalities that the environmental communities want us to factor in, through the management of the industry from all perspectives.

Senator McInnis: I arrived early and had a wonderful in camera meeting with the gentlemen at the head of the table. It was quite advantageous. I needn't show up next week.

User fees, as Senator Munson rightly points are, are things we don't talk about much here, but I did want to ask you this: What kind of licensing and access to the ocean fees do we have in Atlantic Canada, for example? And what would be the quantum or total amount of revenue that you might get out of B.C.?

Mr. Stringer: Are you talking about in aquaculture?

Senator McInnis: Yes.

Mr. Stringer: In aquaculture, the fees are set by the provinces, not by the federal government.

Senator McInnis: I didn't know that.

Mr. Stringer: They're set by the provinces. Each of the provinces, of course, has a different regime. In the B.C. proposal before you, we tried to make sure that they're not way out of line with what's happening in the rest of the country, and we think we've succeeded in doing this. The proposed B.C. licence fee is at the high end of the national scale, but not significantly higher, and not much higher than what we see in Norway — in fact, below what's in Norway and Scotland and Chile, which are the main ''competitors'' in the world.

As we've been talking, these guys have dug up the actual numbers, so what we've got in other provinces are?

Mr. Gilbert: On average, in B.C. for a finfish venture, for instance — and by ''average'' we mean annual production of roughly around 2,500 tonnes a year, the fee we're imposing on the industry would be $6,300, on average. In New Brunswick, it's a little less than that. It's around $3,500. In Newfoundland, it's about the same ballpark as it is in Nova Scotia.

As Kevin just said, in B.C. it's a little bit higher, but it's not higher than it used to be when the provincial government was collecting those fees four years ago. We maintained the same level playing field, if I may say so.

To answer the second part of your question, all together, if we would collect the fees tomorrow morning, we would gather roughly $800,000, which is roughly what the provincial government was collecting four years ago.

Senator Raine: You just gave us some statistics on what the different provinces were doing. It would be helpful if you could give us a chart so we would have that in written form, not only of the different Atlantic provinces but also Norway, Scotland and Chile, which are our main competitors. It's good that what you're doing is kind of rationalizing what was already being done in B.C., not higher, not lower, but similar.

That's really all I have to ask. Thank you.

Mr. Stringer: We'd be happy to provide it. It may already be in the materials we've sent, but we'll make sure we're highlighting it and pointing out where.

One thing I will say is that it was a fairly obvious thing to look at: Let's take a look at what Norway's fees are. But it is such a different basis. We've done the comparison that we can, and we'll make sure we're highlighting that in the package that you have.

The Chair: I may have missed the question, but what is the earliest date for the implementation of the aquaculture licence fees?

Mr. Stringer: It's part of the user fee process. Once the committee gives its recommendations, if there are no major changes that we're asked to do and we're not asked to go back and rethink the fees, then it goes to a regulatory package that goes to Treasury Board. Once it gets heard at Treasury Board, it depends if there's a Canada Gazette Part 1 process. Because we've already had extensive consultation, if that process doesn't have to take place, you can go straight to Canada Gazette Part II. But the regulation needs to be written up now, coming out of this committee's report. Once that's done, it goes to Treasury Board and then it can be put into the Canada Gazette and it's made the law of the land.

The Chair: We'll take a few moments to let our witnesses depart, and then we'll go in camera to deal with these issues.

(The committee continued in camera.)


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