Keystone Agricultural Producers (KAP) is Manitoba’s general farm policy organization, representing and promoting the interests of thousands of agricultural producers in Manitoba. Our membership consists of over 6,000 members and 25 commodity groups who set our organization’s policy through a grassroots governance structure.
KAP considers the use of Crown land to be important for livestock enterprises in Manitoba. KAP’s position is that agricultural crown land should be available to Manitoba farmers and that it is managed sustainably to its full production potential.
This submission outlines KAP’s position on certain aspects of the proposed changes to the Agricultural Crown Lands Leases and Permits regulation. The comments included in this submission were developed through KAP’s Livestock Committee and are in addition to KAP’s April 2018 submission.
We request Manitoba Agriculture provide the results of its consultations, the draft regulation and impact assessment.
KAP’s position has long been that eligibility requirements should preference Manitoba farmers in lease applications.
Our members suggest that eligibility should be granted only to individuals and not to corporations, as doing so would greatly simplify the regulatory development process. Feedback from committee members indicates that those who are incorporated but have crown lands leased to an individual have not encountered any practical problems with this arrangement.
We support the wording proposed by Manitoba Agriculture that an individual must be actively involved in the “haying, grazing, or cropping” of the leased lands in order to be eligible to lease Crown lands. However, we would suggest adding the word “intended” ahead of “haying, grazing, or cropping” to acknowledge that the individual can only be involved in these activities once the lease is acquired.
As far as determining eligibility, our members are in favour of requiring an Environmental Farm Plan, as this would be good for public trust and demonstrate responsible land stewardship. One other requirement would also be needed, such as those suggested by Manitoba Agriculture (i.e. registration certificate for the verified beef production plus program, proof of enrolment in Western Livestock Price Insurance Program, or similar agricultural insurance program, a current account number for AgriStability or AgriInvest, or proof of membership in a farm organization). This would demonstrate that the applicant is a bona fide farmer and not require the disclosure of additional personal information, which would help to reduce red tape.
We suggest that the determination of eligibility should be done prior to the auction, for example 30 days beforehand.
KAP’s policy is that the 4,800-animal unit month limit currently placed on farmers using Crown lands can be modernized to reflect current farming practices and operational capacity.
Our members agree that the AUM limit should be increased and suggested a limit of 10,000 AUMS per applicant, which should be reviewed periodically to ensure it reflects current farming practices and operational capacity.
Lease Terms and Rental Rates
KAP believes that the lease terms are too long. This restricts the opportunity for new entrants to participate in the Crown lands leasing program.
There is some debate amongst our members as the best way to strike the balance between making Crown Lands available versus ensuring longevity and stability. With that being said, our members tended to agree that a shorter lease length with first right of renewal would appease both sides.
The committee wants to see producers who invest in the improvement of Crown Lands be compensated for their efforts, whether this be through a right of first refusal, reimbursement, etc.
As for the rental rate, the committee suggested having the rate be market driven and determined.
For the allocation of casual permits, we suggest the use of a lottery as this process would be the simplest and fastest. Finally, we would like to reiterate previously expressed concerns that an auction system does not favour young farmers, and we would encourage the department to develop programming to assist young farmers.
On behalf of KAP, thank you for your consideration of this submission. We appreciate the opportunity to be involved in the regulatory development process.