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
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