OFA submitted comments to the Ontario Standing Committee on Finance and Economic Affairs regarding Schedules 1, 4 and 7 of Bill 46: Less Red Tape, Stronger Ontario Act, 2022.

With respect to Schedule 1, OFA supports the proposed amendments to the Animal Health Act, 2009 (AHA). These amendments include allowing the Ontario Minister of Agriculture, Food and Rural Affairs to issue a temporary response order respecting specific hazards, including animal health emergencies, upon advice from the Chief Veterinarian for Ontario. A temporary response order, effective for up to 72 hours, would work to protect human and animal well-being in a timely and effective manner when faced with a potential animal health crisis, especially in the initial phases of an emerging animal health event. OFA supports enabling the Minister to extend the temporary response order for an additional 72 hours upon the recommendation of the Chief Veterinarian for Ontario, should the criteria for issuing the order continue to exist.

With respect to Schedule 4, OFA is supportive of granting lenders, holding Feeder Cattle Loan Guarantee Program (FCLGP)- supported loans, a priority security position ahead of custom feeders who may rely on the Innkeepers Act provisions with respect to cattle enrolled in the Ontario FCLGP. However, we do not support the proposed amendment to the Ministry of Agriculture, Food and Rural Affairs Act to exempt cattle enrolled in the FCLGP from section 3 of the Innkeepers Act. Such an exemption would prevent custom feeders from having any such lien on the cattle as well as preventing custom feeders from being able to seize and sell the cattle for unpaid services. Instead, OFA recommends that provisions in the Innkeepers Act continue to apply, albeit subordinate to lenders with respect to FCLGP-supported loans.

Regarding Schedule 7, OFA supports the new Ontario Society for the Prevention of Cruelty to Animals (OSPCA) Corporation Act, 2022, which would clarify the corporate status of the OSPCA.