Pullet Growers of Canada Detailed Request for Part II Agency Status

Pullet Growers of Canada Detailed Request for Part II Agency Status
Under the Farm Products Agencies Act
Farm Products Council of Canada
Public Hearing, Wednesday, May 22, 2013
Winnipeg, Manitoba
Interveners on behalf of the British Columbia Egg Marketing Board
Name and Full Address
Mr. Randy Friesen
Manager, Production and Research
BC Egg Marketing Board
250-32160 South Fraser Way
Abbotsford, BC
V2T 1W5
Are you a pullet producer?
No
Are you a member of the Pullet Growers of Canada?
No
Name and Full Address
Mr. Harvey Sasaki
President
Agri-Saki Consulting Incorporated
568 Leaside Avenue
Victoria, BC
V8Z 2K8
Are you a pullet producer?
No
Are you a member of the Pullet Growers of Canada?
No
Farm Products Council of Canada
Public Hearing
Winnipeg, May 22, 2013
BC Egg Marketing Board
1
British Columbia Position
 British Columbia Egg Industry
 Stakeholder Engagement in British Columbia
 Views and Perspectives

Pullet only growers
Egg industry value chain and pullet growers with
licenced egg production

Informed decision making
BC Egg Marketing Board
2


Stakeholder Engagement
 Initiated a BC Stakeholder Engagement Strategy, including hosting of
sessions between the BC industry and PGC, February 21, 2013
 Sought to make the BC egg industry aware of the Pullet Growers of
Canada’s proposed agency
 Sought the input from the BC industry to provide to the Farm Products
Council of Canada with British Columbia views and perspectives
Why British Columbia is not a member of the PGC
 Formally approached in May 2011 and April 2012
 Need for greater consultation with producer members regarding
the specifics of how such an agency could operate in BC
 Concern with adding unnecessary or additional operating costs
 Organizing under the umbrella of the Egg Farmers of Canada would
be more cost effective
BC Egg Marketing Board
3


130 registered producers; 2.4 million laying hens; 64 million
dozen eggs; $95 million to BC economy
BCEMB authorized to regulate pullets in BC, but has not
introduced any regulations as there has been no demonstrated
need expressed by pullet producers in BC
 Four pullet producers without egg quota – < 5% of total production.
 British Columbia highly dependent on eggs and chicks imported from the
United States for pullet production
 Nearly 50% of pullets produced, sourced as chicks from the United States
1,254,494 of 2,614,521)
 Majority of production by those with layer quota for own use and for other
producers using existing barn capacity.
 No known excess or surplus production over licenced layer requirements
 No known situations of pullet producer conflict over the price received for
pullets
BC Egg Marketing Board
4

BC Egg Marketing Board facilitated engagement on
the PGC request for Part II agency status
Formal session held on February 21, 2013 in Abbotsford
 PGC invited to participate and present the detailed request
 While three separate sessions were planned, only one was attended
by industry
 11 industry representatives, egg producers, egg producers growing
pullets, hatchery, graders and feed company
 Pullet producers without egg quota were invited but did not attend

Follow-up post session direct contact with a pullet
producer without egg quota
BC Egg Marketing Board
5
Agree with PGC issues raised, “true” cost of
production not reflective of prices received
 Represent a very small minority of production
 These producers feel a general lack of

Power to “negotiate”
Respect for the important role played by pullet growers
Utilize existing facility capacity; returns insufficient to
consider reinvestment
 Understand and respect need to meet market
specifications, with or without National Agency

Must be responsive to client needs.

Welcome a plebiscite on the proposed national
agency.
BC Egg Marketing Board
6
BC is different
 Need to consider the cost to consumer, irrespective of
how small; a very delicate issue in BC
 Perceived value not demonstrated
 Provincial quota allocation must match provincial layer
allocation
 System fluidity to respond to changing market
conditions
 Assurances that current import supply of chicks will
not be impacted or subjected to import controls
 Respect for provincial due process in assessing need
and value of provincial participation in a national
system

BC Egg Marketing Board
7
Request lacking in detailed information to enable an
“informed decision”
 Degree of support in BC – no clear indication from BC
pullet growers of support
 Effects on operations of egg producers and pullet
growers - - additional regulatory layer on producers that
does not currently exist
 Due regard for the interests of all
 No quantitative analysis of impacts to producers or consumers
 No engagement beyond pullet producers and regulators
 No regional assessment or sensitivity analysis of implications of even a
one cent per dozen increase in the cost of eggs on consumption.
BC Egg Marketing Board
8
Insufficient details regarding:
 The marketing plan and required cooperation
 Principles of Federal/provincial agreement
 Operating agreement
 Quota allocation/quota formula
 Levy system

Consistency with trade obligations
 Implications, particularly intentions and details with respect to
“import controls”

No comprehensive benefit/cost analysis of the proposed
agency and assessment of alternate mechanisms to
achieve the outcomes.
BC Egg Marketing Board
9


Due diligence required
 Stakeholder Engagement Strategy only part of the process
 Complete information and data set required to fully analyze the
implications
BCEMB unable to represent to its supervisory body and provincial
government that the application serves to enhance the broader
public interest, particularly as it relates to consumer impacts and
effects
 Input far from complete, in particular viewpoints of the 4 pullet growers
without layer quota
 Lack of detailed information as indicated in the March 5 submission
 Insufficient detailed information to satisfy the FPCC published lines of
enquiry or the federal regulatory impact assessment requirements
 Lack of specific details on the key components of a federal/provincial
agreement

The pullet system in British Columbia
 Differs from other provinces
 Currently works in providing healthy quality pullets at a price acceptable
to pullet growers and egg producers
BC Egg Marketing Board
10
Questions?
BC Egg Marketing Board
11