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Support innovators as they navigate the regulatory environment

Question:How can regulations be designed to promote innovation across key sectors?
on 12/02/2016 1480715743
INTRODUCTION Mining is an industry that has built-in dangers not seen in all sectors, especially in ultra-deep environments below 2.5km underground l .... Read more

INTRODUCTION

Mining is an industry that has built-in dangers not seen in all sectors, especially in ultra-deep environments below 2.5km underground like those addressed by the Ultra-Deep Mining Network (UDMN).  Rock can shift, air quality could change, and equipment might fail with catastrophic consequences.   As such, mining companies are naturally risk averse, focused on safety, and Canada’s regulatory environment serves an important role in building trust in the quality and safety of new innovations.

CHALLENGES

There are arguments against simplifying and streamlining Canada’s regulatory environment.  In mining, regulations act as an important barrier to competitive entry and enable risk taking SMEs to capture commensurate rewards that drive further innovation.   While more entrants could be attracted to the mining industry if regulations were to become less onerous, this could be at the expense of safety, the environment, and the innovation landscape.

SOLUTIONS

By providing support to innovators seeking to navigate the regulatory landscape, the government could focus on offsetting the costs and administrative time delays associated with getting certifications and incentivize mining companies to simplify and streamline their procurement processes for Canadian innovators.  Plus, by supporting networks that provide regulatory advisory services to innovators, the government in turn supports vetted innovators technologies that make a difference for the mining industry without sacrificing safety and credibility.

*Note:  For information about the Ultra-Deep Mining Network, please visit: https://www.miningdeep.ca/

Credit: Ultra-Deep Mining Network

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Be able to suspend current laws to allow for innovation and experimentation

Question:How can regulations be designed to promote innovation across key sectors?
on 11/17/2016 1479415458
Did you know that a number of countries have mechanisms to suspend their current laws to allow for innovation/experimentation? Canada should do the sa .... Read more

Did you know that a number of countries have mechanisms to suspend their current laws to allow for innovation/experimentation? Canada should do the same. 

France has a program called “France Experimentation”.  Under France’s program, anyone who has an ambitious and innovative project to market new products or services and whose development is hindered or impeded by certain regulatory provisions can apply. Several experiments were deployed in areas as diverse as social policy, justice, and environmental law. Read more here (Google had to translate the page for me as it is in French): http://www.entreprises.gouv.fr/politique-et-enjeux/france-experimentation

Japan has a program allowing companies to test prototypes of innovative products and services in an area that conflicts with existing regulations: the "System of Special Arrangements for Corporate Field Tests". Under the system, a private company is eligible to make a request to the Japanese government specifying deregulations of the current law which are required for launching new business activities. In response, a competent minister for business and a competent minister for regulation will examine and discuss the request to determine whether or not the request should be approved. This program allowed the Japanese government to respond positively to 9 applications for regulatory flexibility (including 4 from SMEs) that have allowed testing new electric mobility devices on roads in the city of Tsukuba ( http://www.meti.go.jp/english/press/2015/0427_03.html) and increasing the maximum threshold power electric bicycles to facilitate the work of bicycle deliverymen (Yamaha Delivery and Yamato).

In the UK, since May 2016, the "Regulatory sandbox" aims to create a ‘safe space’ in which businesses can test innovative products, services, business models and delivery mechanisms in a live environment without immediately incurring all the normal regulatory consequences of engaging in the activity in question. It is explained in detail in this speech by Christopher Woolard, FCA Director of Strategy and Competition, delivered at the Innovate Finance Global Summit on 11 April 2016.

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An innovative approach to innovation: centering small businesses on the agenda

Question:How can regulations be designed to promote innovation across key sectors?
on 11/04/2016 1478282022
Ensuring that Canadian laws, regulations and standards keep pace with rapid change and promote innovation as well as a business environment that is .... Read more

Ensuring that Canadian laws, regulations and standards keep pace with rapid change and promote innovation as well as a business environment that is conducive to innovation

  • Introduce an “innovation lens” that governments use when implementing new regulations, policies and taxes to ensure that these do not negatively impact a firm’s ability to innovate. This lens will ensure that SMEs won’t have to choose between being compliant and being innovative.
    • Policies should be looked at through an innovation lens to ensure that they do not negatively impact SMEs ability to innovate. They include:
      • Increasing Canada Pension Plan premiums for employers
      • Carbon taxes
      • The cancellation of further reductions to the Small Business Tax Rate
      • Workplace regulation changes that affect productivity (e.g. flexible working hours, statutory holidays, etc.)
  • Make red tape reduction a priority and carefully consider the need for all new regulation and its impact on small business by strengthening the One-for-One rule when implementing new regulatory requirements;
  • Ensure that accountability measures remain in place to ensure that the regulatory burden does not become a roadblock to SME innovation. Continue to publicly measure and report government regulations and include regulatory requirements in legislation and policy as part of the baseline count;
  • Improve government communications, program information and application forms for innovation by ensuring that all information provided is written in plain language. Government officials should also provide straightforward and consistent advice regarding government programs and requirements in a timely manner;
  • Review the government’s Concierge service to ensure that it is providing small business owners with information about all government programs that may be useful or relevant to the work they are doing. Make sure that the service also provides information to SMEs undertaking innovative work outside the high-tech sector;
  • Provide timely and simple feedback and decision-making in cases dealing with funding or other financial matters. Government regulators and customer service agents should be mindful of the unique risks and limitations that small businesses face when seeking financing for innovation;

Promoting the freedom to compete in a global economy and lowering barriers to allow Canadian businesses to prosper at home and abroad

  • Engage with provincial and territorial governments to ensure that the new agreement of internal trade is implemented and eliminates current barriers to labour, goods and services between provinces and territories. Mutual recognition of trades, skills and certifications is a critical ingredient to reducing the shortage of skilled labour for SMEs. Additionally, open borders between provinces will allow for SMEs to grow their market share and better network with other like-minded innovative Canadian companies.
  • Reduce barriers to international trade to allow SMEs better access to new markets and new technologies abroad by cutting red tape at the border and reducing the overall costs of trading. Provide easily accessible and SME-focused information on trade and raise awareness of trade programs and ensure that they are relevant for SMEs;
  • Continue to engage in international trade agreements, such as CETA, that aim to reduce tariff and non-tariff barriers to trade for SMEs such as red tape, discriminatory licences and permits, and certifications. Trade agreements such as these ensure a more transparent, stable and predictable trading and investment environment for small businesses. Additionally, they allow for better technology-sharing with companies outside Canada.

*For full list of recommendations, see attached CFIB report on SMEs and innovation, Beyond the Big Idea: Redefining and Rethinking the Innovation Agenda 

Credit: Canadian Federation of Independent Business

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IP ownership for government-funded space R&D

Question:How can regulations be designed to promote innovation across key sectors?
on 10/27/2016 1477605655
The National Aeronautics and Space Administration (NASA) in the US is explicitly mandated to ensure that the intellectual property generated over the .... Read more

The National Aeronautics and Space Administration (NASA) in the US is explicitly mandated to ensure that the intellectual property generated over the course of work supported by NASA grants and funding remains with the company, and not (exclusively) with the US government.  Moreover, NASA makes it policy to not stockpile patents, but make the results of their research and development freely available to American industry.  Their overarching objective is to ensure that the benefits of NASA funding are returned to American industry.  NASA makes their database of technical reports freely available on line, and recently made their entire catalogue of all software programs and tools developed through NASA work available, free of charge, to American companies. 

Here in Canada, the Canadian Space Agency has no such mandate and it is common for IP generated by companies or organizations supported by CSA funding to belong to the federal government, and not to the company that created it.  Lack of ownership of IP is a serious disincentive to companies, and much valuable research thus becomes locked away and never progresses anywhere or benefits anyone. 

The Canadian Government should give the Canadian Space Agency the same clear mandate that NASA has, to work as a partner and facilitator to Canadian businesses and organizations and support technology transfer to Canadian entities.  IP generated through CSA-funded work should as a rule be retained by the company or organization that performs the work.

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Update policy to unlock Canada’s social assets

Question:How can regulations be designed to promote innovation across key sectors?
on 10/27/2016 1477603767
Canada’s charities and nonprofits are essential actors for successfully deploying inclusive innovation, developing both frontline and systems in .... Read more

Canada’s charities and nonprofits are essential actors for successfully deploying inclusive innovation, developing both frontline and systems innovations that advance and distribute our collective prosperity. Unfortunately, the federal charity regulatory regime currently encumbers this sector’s innovation prowess. A set of reforms would unlock critical social assets across Canada:

  1. Create an arm’s length agency to replace Canada Revenue Agency - Charities Division as the regulator for charities and nonprofits.
  2. Modernize treatment of charity/nonprofit earned income (unleashing growth of nonprofit social enterprises).
  3. Replace the “direction and control of funds” test for charitable grants with a “destination of funds” test to make it less difficult to do charitable activities with multi-sector, innovation partner-based arrangements.
  4. Legislate a new form of incorporation for blended or shared value companies, such as British Columbia’s Community Contribution Companies.
  5. Implement a federal social procurement policy to assist scaling existing and future evidence-based social innovations that positively transform outcomes for Canadians.
Credit: Social Innovation Generation

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Facilitating entrepreneurial aerospace innovation by leveraging government facilities and expertise

Question:How can regulations be designed to promote innovation across key sectors?
on 10/27/2016 1477542291
Innovation in the aerospace sector is often perceived as being dominated by large companies and government agencies, but historically a great deal of .... Read more

Innovation in the aerospace sector is often perceived as being dominated by large companies and government agencies, but historically a great deal of innovation has come from outside of these channels.  Such fundamental inventions as the airplane and the liquid-propellant rocket were the work of individuals and amateurs, and many of the people who were instrumental in the early days of both aviation and space exploration got their start working either individually or as part of small groups of like-minded enthusiasts. 

Today this trend is continuing with the rapid development worldwide of unmanned aerial vehicle (UAV) technology, low-cost spacecraft and space launch technology, among others, and much of that work is being driven by small startups, student and amateur groups, and even individuals.  Yet here in Canada, these innovators are severely handicapped by a lack of support.  

One invaluable means by which the government could, at little to no cost, encourage the work of such innovators would be to mandate that, where possible, government facilities such as Canadian Forces bases, NRC or CSA facilities be made available to support their work.  As one example, student and amateur groups, small startups and private innovators would benefit enormously from having access to large areas such as CF bases to fly experimental UAVs, launch small rockets and test experimental propulsion systems.  For most small groups or individuals with very limited resources, access to a suitable large, secure area with clear airspace that is reasonably accessible can be a severe and oftentimes insurmountable challenge.  The government however has access to many such spaces that would be suitable and safe, as well as to experienced personnel and experts whose expertise and knowledge of safety might be a benefit. 

Other countries like the United States have a well established culture of amateur aerospace innovation and many facilities such as the Mojave Air & Space Port and Spaceport America are available to such non-corporate innovators and student groups who would not be able to pursue their projects otherwise.  That relative ease of access has both enabled invaluable hands-on experience to be gained, and has also been instrumental in facilitating the creation of many startup companies, including the well-known Virgin Galactic and SpaceX.  An easy way to achieve some of the same benefits here in Canada at little cost to the government would be to promote the use of existing government land and facilities to play host to experimental unmanned flights, launches and tests, and put in place a simple, efficient process by which groups, individuals and small startups can gain permission for that use.

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Harmonization and the pre-eminence of the national model building code development process

Question:How can regulations be designed to promote innovation across key sectors?
on 10/19/2016 1476892634
Tags:
The harmonization of codes, standards, and trades qualifications across jurisdictions increases labour mobility and productivity, reduces costs and pr .... Read more

The harmonization of codes, standards, and trades qualifications across jurisdictions increases labour mobility and productivity, reduces costs and promotes innovation. The federal government must continue to support and encourage the elimination of inter-provincial trade barriers.

 

For the residential construction industry, the government should ensure that changes in building code requirements do not adversely impact housing affordability. Federal research in housing, both for innovation and in support of codes, standards and regulations, should focus on performance improvements that either reduce or keep construction costs the same.

The National Building Code of Canada, which is the backbone of building codes and regulations across Canada, supports harmonization, productivity and efficiency. However, it is chronically underfunded and needs additional support to properly support innovation without eroding affordability.

Federal, provincial and territorial governments should affirm the pre-eminence of the national model building code development process (including the key roles of the Canadian Commission on Building and Fire Codes, the Canadian Construction and Materials Centre, and the Industrial Research Assistance Program) as it pertains to the residential construction industry.

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Sustainable Growth with the Canadian High Speed Rail Transportation Strategy

Question:How can regulations be designed to promote innovation across key sectors?
on 10/12/2016 1476242778
Canada is a beautiful and vast nation. The majority of the Canadian population lives in urban centers like Montreal, Toronto and Vancouver. Unfortunat .... Read more

Canada is a beautiful and vast nation. The majority of the Canadian population lives in urban centers like Montreal, Toronto and Vancouver. Unfortunately, this puts significant strain on our infrastructure and requires consistent funding by all level of government to modernize.  I find that most of our tax dollars are devoted to fund the same old projects – i.e., build or revamp highways, etc. Hence, I propose that we re-examine and develop a new high speed rail strategy.  Just imagine a world where an individual can live in Montreal and commute to Toronto for work and be back home on time for dinner with the family or a student that does not have to take on more debt to live in Ottawa just so they can purse a Bachelor degree at University of Ottawa instead the can live with their parents in Montréal.

Overall high speed rail can have many indirect benefits in our economy from reduction in house prices in high density metropolitan areas as people will be able to live further away and it can also create a multiplier effect on small businesses as they can flourish in smaller city which can be used as stop over hubs for longer commutes between Montreal to Calgary. Moreover, we can re-train all the journey / trades men or women that have been out of work to help build the high speed rail infrastructure.  Not only will this strategy lead us in the right direction in regard to meeting our international emission targets but it will also create green manufacturing jobs of the future. I look forward to discussing this idea with other like-minded Canadians.

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Provincial differences seen as innovation hurdle

Question:How can regulations be designed to promote innovation across key sectors?
on 10/11/2016 1476218034
Tags:
"It would be good if in Canada we had one common financial regulatory regime that made it easy for a startup to do business in all the different provi .... Read more

"It would be good if in Canada we had one common financial regulatory regime that made it easy for a startup to do business in all the different provinces of Canada, instead of having to satisfy potential regulators,"

"The provincial control over financial regulation is a minor [impediment]" he said.

http://www.infomedia.gc.ca/ic/articles/unrestricted/2016/10/ic2016103487957_2034.htm

Provincial differences seen as innovation hurdleHill TimesOctober 3 2016

Credit: James Brander, a professor at the Sauder School of Business at the University of British Columbia

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Reduce and have efficient regulations

Question:How can regulations be designed to promote innovation across key sectors?
on 10/06/2016 1475721161
Tags: accelerators 
Before putting new regulations in place,there should be a consultation as broad as possible : maybe the regulation is not needed or the regulation doe .... Read more

Before putting new regulations in place,there should be a consultation as broad as possible : maybe the regulation is not needed or the regulation does not pass the cost-benefit test.Every year, there should be a review of existing regulations : the obsolete, ineffective regulations should be abolished.

Credit: MacDonald-Laurier Institute, Cato Institute

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Promote innovation in order to empower SMEs and facilitate inclusive growth

Question:How can regulations be designed to promote innovation across key sectors?
on 09/30/2016 1475268194
QUESTION: HOW CAN WE EMPOWER CANADA’S SMES AND PROMOTE INCLUSIVE GROWTH? According to Statistics Canada, there are just over one million busin .... Read more

QUESTION:

HOW CAN WE EMPOWER CANADA’S SMES AND PROMOTE INCLUSIVE GROWTH?

According to Statistics Canada, there are just over one million businesses in Canada, 99.8% of which are small or mid‑sized firms.  Between 2005 and 2015, small business created 1.12 million jobs, which accounted for 87.7% of all net new jobs created during that time period.  In order to further contribute to the economy, Canadian SMEs in every corner of the country need access to simple, affordable tools to start, run, and grow their businesses – from accepting credit cards and invoicing to tracking inventory and real-time analytics.  

SUGGESTION:

PROMOTE INNOVATION IN THE FINANCIAL SERVICES AND PAYMENTS SPACE

There are many different players in the financial services landscape in Canada.  Regardless of where these institutions come from, it is important for the Canadian government to ensure that government and industry regulations or standards encourage new entrants to introduce innovative small business solutions to the market.  Doing so allows companies like Square and other innovative industry participants to:

(1) Leverage technology for ease of doing business

Square started by providing free credit card readers, a simple sign-up process, free data analytics and a clear and simple fee structure.  From there, our offering has evolved to a full suite of services, including APIs for developers.  

(2) Promote an entrepreneurial and creative society

Square’s technology empowers anyone, anywhere, to become an entrepreneur and turn their crafts into a business.  Square sellers include mountain bike rental shops in the Yukon, axe throwing clubs in Calgary, produce markets in New Brunswick and the Pride Parade in Toronto.

(3) Use innovation to promote inclusive growth and a digital world

Square is bringing many Canadian small businesses online and enabling them to take credit card payments for the first time. Of Square’s sellers in Canada, seventy per cent have never taken a credit card payment before using Square.  Square’s products promote a digital world one where business can learn from their own data and coffee shop owners no longer have to count dirty coffee cups to gauge their inventory.

Square serves hundreds of thousands of merchants all over Canada.  Square Canada has offices in Kitchener-Waterloo and Toronto, employing 60 Canadians, with room to grow!

 

Credit: Square

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Advancing Canada's Innovation Funding Ecosystem through Enhancements to SR&ED and other Related Programs

Question:How can regulations be designed to promote innovation across key sectors?
on 09/30/2016 1475215562
Tags:
PwC's thoughts on how to enhance the overall innovation funding ecosystem in Canada through changes to the SR&ED program and the introduction or enhan .... Read more

PwC's thoughts on how to enhance the overall innovation funding ecosystem in Canada through changes to the SR&ED program and the introduction or enhancement of complementary direct funding innovation programs. Please see the attached file.

Credit: PricewaterhouseCoopers LLP

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How can regulations be designed and used to drive innovation across key sectors?

Question:How can regulations be designed to promote innovation across key sectors?
on 09/29/2016 1475178052
Regulations help create the society we desire by protecting our health, the environment, our privacy, and the rights of consumers and citizens. Poorly .... Read more

Regulations help create the society we desire by protecting our health, the environment, our privacy, and the rights of consumers and citizens. Poorly designed regulations, though, can have unintended consequences such as stifling new technologies, business models, products and services.

 

Canada’s federation has a history of complicating the picture further by creating different, and sometimes incompatible, regulations in different provinces and territories which carve up the country’s relatively small and geographically dispersed marketplace into even less economical markets. This can present enormous difficulties for innovative firms trying to scale up to become internationally competitive.

 

We applaud Canada’s premiers for achieving agreement on a proposed Canadian Free Trade Agreement to replace the imperfect Agreement on Internal Trade. While we eagerly await details of the agreement, we are encouraged to hear that it includes a process for addressing regulatory barriers to trade. And perhaps even more importantly in an era of disruptive technologies, a process for cooperating to jointly develop new regulations.

 

Harmonizing or converging regulations between jurisdictions is not an easy process, but the results are worth it. The CPA profession serves as a practical example of the benefits of regulatory harmonization. CPA Canada and provincial and territorial CPA bodies have jointly developed national standards for qualification and professional conduct which ensures that the public benefits from the same consistently rigorous standards throughout the country. And just as importantly, CPAs are able to move freely around the country and work in all jurisdictions as a result of those nationally harmonized standards.

 

Earlier in this paper, we discussed the role of government procurement in building demand for Canada’s innovations. Just as important as the government’s buying power is the need for regulations that encourage innovative ideas to flourish. At a business roundtable event a couple of years ago, the president of a small manufacturing company told us how government regulations impact his product offerings.

 

“We operate in two distinct areas, one is heavily regulated and the other is not,” he said. “One of the things we find is that the market that is not regulated, we are able to bring a lot of cool new products to the marketplace. In the other market, innovation is really stifled because of regulations and an unwillingness at all levels of government to be open to innovation….The product in the unregulated market is just night and day better.”[1]

 

The key to effective regulation is to ensure the public is adequately protected without being so overly broad that new ideas are quashed. It’s not easy. Neither is the regulatory process nimble enough to keep up with the pace of technological change. But if regulators could develop an early adopter mindset and a lightness of touch, perhaps essential regulations would be less of a barrier to innovation.

 

Recommendations:

 

  • Building on the momentum of the proposed Canadian Free Trade Agreement, we encourage Canada’s federal, provincial and territorial governments to continue to harmonize, converge or mutually recognize differing regulations in order to strengthen Canada’s economic union. When new regulations are being developed, we encourage governments to work cooperatively to develop consistent regulations across jurisdictions.      

 

What new approaches could be explored to improve government services to businesses? Who are the partners?

 

Canada’s CPAs occupy decision-making roles in businesses and organizations of all types. We encourage you to think of them as both a source of expert business knowledge and advice, and also as a potential conduit for reaching the business community. In that vein, a one-stop conduit offering easy access to the range of government programs and services for businesses is something business people would welcome.

 

Government is already doing a great deal to support innovation, with a wealth of programs that address access to finance, international trade, research and development, and advice to entrepreneurs. So much so that entrepreneurs are overwhelmed. Programs are offered through a variety of government departments and agencies, at all three levels, and small business operators, in particular, tell us they find it too challenging and time consuming to even understand all that is available to them. A “one window” or “concierge” approach to delivering government programs is always a popular suggestion from business.

 

The Jenkins report made a number of important observations about program efficiencies and the need to perhaps rationalize the range of programs available. The report also recommended a “concierge” service for assisting innovative firms.

 

Government has obviously heard this message and we commend the recent efforts to present a more coordinated and streamlined public face to government programs. In particular, the Canadian Trade Commissioners Service, the Business Development Bank of Canada, Export Development Canada and the Canadian Commercial Corporation offer a range of programs and services that are complementary. In the past couple of years, they have demonstrated a willingness to work more collaboratively in order to provide better customer service. We encourage greater collaboration between government departments and agencies. We also encourage government to consider private sector partners, when appropriate, for delivery of services.  

 

An innovation that would benefit both government and business is Standardized Business Reporting. As noted in our pre-budget submission to the House of Commons Standing Committee on Finance, Standardized Business Reporting using eXtensible Business Reporting Language (XBRL) would reduce the administrative burden faced by businesses dealing with government. It would also enable government to be more responsive and would facilitate easier exchange of information between government departments.

 

Recommendations:

  • Improve collaboration between government departments and agencies to more effectively communicate and deliver government programs to businesses. In particular, consider developing a “concierge” service that provides business with relevant information on the full range of government programs related to innovation.
  • Adopt Standardized Business Reporting using eXtensible Business Reporting Language (XBRL) across government departments and agencies for use by businesses for all government filings. 

 

Finally, as a 2009 report of the Council of Canadian Academies notes: “There is no single cause of the innovation problem in Canada, nor is there any one-size-fits-all remedy. Public policy in respect of innovation therefore needs to be informed by a deep understanding of the factors that influence business decision makers, sector by sector. This requires consultation with business people themselves, as well as the further development of innovation surveys and other forms of micro-analysis of the innovation process.”

In that spirit, we hope this consultation on Canada’s innovation agenda is the start of an ongoing dialogue.

 

[1] Talking Trade: Summary Report of the CGA-Canada Roundtables on International Trade, CGA-Canada, July 2014.

Credit: Chartered Professional Accountants of Canada

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Remove barriers to collaboration between government scientists and university researchers

Question:How can regulations be designed to promote innovation across key sectors?
on 09/28/2016 1475079203
Publicly funded research in Canada happens in two places for the most part, in universities, and in government departments and agencies. There is a gr .... Read more

Publicly funded research in Canada happens in two places for the most part, in universities, and in government departments and agencies. There is a great deal of collaborative potential, between these players, as well as community and industry partners, for breakthrough discoveries, impactful applied research, training of the next generation of top researchers and innovators, and potential innovative spin-offs with major economic and social potential. However, there are sometimes policy barriers to effective collaboration (e.g. intellectual property policies, funding arrangements, etc.).

The federal innovation review should look into ways of improving and streamlining collaboration between government departments and agencies, universities, and community and industry partners.

Credit: Memorial University of Newfoundland

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Copyright Board reform is needed

Question:How can regulations be designed to promote innovation across key sectors?
on 09/28/2016 1475074331
Tags:
In order for the creative industries to thrive, Copyright Board reform is urgently needed. Canada’s current Copyright Board process is too slow .... Read more

In order for the creative industries to thrive, Copyright Board reform is urgently needed. Canada’s current Copyright Board process is too slow and too unpredictable, creating a barrier to business. Stakeholders representing both users and rights holders met in Ottawa in May 2016 at the ALAI Symposium entitled, “The Copyright Board of Canada: Which Way Ahead?”, and the outcome was unanimous: stakeholders, experts, academics and legal participants all agreed that the Board’s proceedings are currently prohibitively slow.  The Board’s attempt to address delay issues in 2012 has, after four years, produced no tangible changes. Changes to the Copyright Board’s operations, procedures and processes must be made to ensure that, among other things, proceedings have a defined timeline, that the evidence provided to the Board by experts is reflected in their decisions, and that there are prescribed rate-setting criteria, none of which are presently the case. To do business in the digital era, rights holders and users alike require fast, predictable and marketplace-based valuations.

Credit: Music Canada

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Review and revise existing mining regulations in light of new technologies

Question:How can regulations be designed to promote innovation across key sectors?
on 09/23/2016 1474661152
Tags: mining 
The government should review existing mining regulations in light of new technologies and techniques that have replaced the realities of early centu .... Read more
  1. The government should review existing mining regulations in light of new technologies and techniques that have replaced the realities of early century mining.
  2. A process should be put in place for innovators to challenge existing regulations.
  3. Engagement process with mining companies, mining service and supply innovators etc. with government regulators. Together, we can better understand both sides and create new strategies on implementing regulations that work in the mining sector.
Credit: Centre for Excellence In Mining Innovation, CEMI

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Trade Priorities, Intellectual Property and Resource Allocation

Question:How can regulations be designed to promote innovation across key sectors?
on 09/19/2016 1474323154
The digital economy is borderless and provides businesses in Canada an unprecedented ease to reach a global consumer base in foreign markets. However, .... Read more

The digital economy is borderless and provides businesses in Canada an unprecedented ease to reach a global consumer base in foreign markets. However, trade barriers, customs tariffs, weak intellectual property laws and other protectionist policies abroad can severely impact and limit Canadian businesses.   For entertainment software, high tariffs (of up to 30 percent) and additional taxes in certain foreign markets translate into higher prices for software, consoles, and peripherals, and can dampen demand for legitimate products, hampering the growth of the Canadian industry. 

Open markets abroad and the ability for data to flow freely across borders are vital to both the development of Canada’s digital economy and the continued growth of the Canadian entertainment software industry. ESAC supports efforts to break down trade barriers via treaties and trade agreements and measures to ensure that restrictive data-localization requirements and other impediments to open cross-border data flows are kept out of these agreements.

Furthermore, Canada should ensure that Canadian companies developing digital products, services and delivery methods have equitable access to foreign markets by seeking consistent and favourable treatment for digital goods and services and international agreements, and seeking to bolster intellectual property protections in export markets with high piracy rates.

ESAC strongly supports high ambition initiatives such as the Canada-EU Comprehensive Economic and Trade Agreement (CETA) and Canada’s participation in the Trans-Pacific Partnership Agreement (TPP). ESAC applauds the Government’s support of the WTO’s Information Technology Agreement to include game hardware and software and digitally delivered products and services.

With that said, intellectual property (IP) is valuable currency in the digital economy, and intellectual property laws are the only means to protect Canadian innovation globally. Creative industries rely on their valuable IP assets for growth and prosperity which is why they must retain the full capacity to develop, commercialize, and protect their intellectual property.[1] Accordingly, having an up-to-date intellectual property framework that recognizes these needs is crucial to the development of a market-driven digital economy.

Canadian game developers and publishers are clearly world leaders in innovation and creativity. These companies are in the business of creating, financing and commercializing intellectual property and developing, marketing and selling an array of entertainment software products and services to a wide range of consumers. Consequently, intellectual property is the cornerstone of the industry, and strong protection and enforcement of intellectual property rights is crucial to the continued growth and success of the industry.

Online piracy continues to undermine our industry and negatively impact revenues, and our industry’s growth potential. As a result, we continue to require new tools and solutions to curtail the occurrences. A robust legislative IP regime that provides adequate and effective protection for creative works in the digital environment is part of this equation and benefits both businesses and consumers by providing greater certainty in digital marketplace and permitting market forces to operate properly - spurring investment in the development of new digital products, services and distribution methods and support a diverse range of new and innovative digital business models, fostering legitimate competition, more consumer choice and lower prices.

According we recommend that the federal government:

  1. Update copyright legislation to ensure it has “teeth” and support cooperative dialogue between content owners and ISPs; and,
  2. Ensure customs officials and law enforcement receive the necessary training and resources to effectively combat piracy both at the border and at the retail level.
i.                    Update copyright and support cooperative dialogue between content owners and ISPs

The Copyright Modernization Act includes strong legal protection against the circumvention of technological protection measures (“TPMs”) used to protect copyrighted works and sets out liability for those who enable copyright infringement. These changes have been important to our industry, where extensive use of sophisticated TPMs to protect products is the norm.

However, while generally supportive, we remain concerned about the long-term effectiveness of the new "notice and notice" to decrease levels of online piracy.   While we acknowledge the educational benefits of notices in individual cases of infringement, without any effective sanction for non-compliance we are deeply concerned that notices will simply be ignored. We remain of the view that "notice and takedown" is a more effective solution for individual instances of infringing content hosted or stored on a system or network, while "notice and notice" is more effective for transitory network communications (such as peer-to-peer file-sharing networks), and that liability limitations should be conditioned on affirmative and effective co-operation with copyright owners in combating online infringements.

ESAC also supports regular, cooperative dialogue between content owners and the ISP community to facilitate collaborative and effective efforts to measure and address infringing activity online. It may be desirable for governments to aid in initiating and facilitating this dialogue, or, where such dialogue fails, for governments to propose appropriate legislation, regulation, or protocols.

ii.                  Ensure customs officials and law enforcement receive the necessary training and resources to effectively combat piracy both at the border and at the retail level

Commercial operations selling devices and offering services that enable pirated and counterfeit video games to be played continue to operate in Canada. In addition, Canada serves as a major transshipment hub for global distribution these devices. This has directly contributed to an unacceptably high level of video game piracy in Canada.

Hard goods piracy, involving the illegal manufacture and sale of counterfeit optical discs for use in consoles or PCs, as well as counterfeit cartridges for handheld devices such as the Nintendo DS / DSi / 3DS, is pervasive and presents a significant threat to the development of a sustainable digital economy. Optical disc piracy remains a challenge, as readily available and inexpensive computer equipment allows anyone to "burn" their own limitless supply of pirated game software.

Furthermore, Canada must provide border officers and law enforcement with the resources and training required to effectively combat piracy both at the border and within Canada, and direct law enforcement, customs officials and prosecutors to give high priority to IPR enforcement, including retail piracy and imports of pirated products, and to seek deterrent penalties against those convicted of these crimes. The federal government should establish and properly fund an IP Crime Task Force, composed of police officers, customs officers, federal prosecutors and stakeholders, to educate, guide and coordinate IP criminal enforcement.

 

[1] This has been recognized by a multitude of government and industry reports. For instance, the Competition Policy Review Panel noted that in the knowledge economy “intellectual property frameworks play a central role in rewarding and encouraging innovation by granting creators the rights that enable them to monetize the products of their innovation,” and determined that modernizing our IP framework in the online environment was especially critical due to the ever-increasing importance of the economic activity associated with the digital economy. Accordingly, the Panel concluded that it was urgent that Canada’s IP framework be updated so that we “develop strong IP capacity and demonstrate to the world how competition and productivity can be furthered by a modern IP regime.” See Competition Policy Review Panel, Compete to Win (June 2008), online: Industry Canada 94-95.

Credit: The Entertainment Software Association of Canada

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Protecting Students' Intellectual Property

Question:How can regulations be designed to promote innovation across key sectors?
on 09/15/2016 1473949725
Tags:
Canadian post-secondary institutions must do more to ensure they are supporting innovation amongst their faculty and students. One area in need of imp .... Read more

Canadian post-secondary institutions must do more to ensure they are supporting innovation amongst their faculty and students. One area in need of improvement is intellectual property (IP) in post-secondary education. IP can be defined as the tangible products of research and creative intellect; the fixed expression of ideas including, but not limited to, inventions, compositions, software, music, art, designs, photographs and processes.

Students, in particular graduate students, often create IP in the course of their studies and research. University policies on the ownership of such property are not consistent, or widely circulated, and are often formed without the student’s best interests in mind. The inconsistency of policy concerning IP at universities and colleges unnecessarily complicates the process of choosing a school or a program of study. These inconsistencies also create barriers for students in innovating and potentially partnering with the private sector. Within Canada, only two institutions have IP policies that support full ownership to the creators of intellectual property – Dalhousie and Waterloo[1], and even in these cases the division between instructors and students is not always clear.

It must also be acknowledged that students are not on an equal footing when negotiating IP rights with supervisors, departments or university administrators. These people often have influence over the student’s access to funding, examination committee recommendations, teaching assistant assignments and letters of recommendation. The power dynamic between the student and their supervisor, department and administration is a direct result of the university structure, and therefore the university has an obligation to ensure that the interests of the student are protected.

Protecting student IP rights is an important element in fostering an innovative process in the post-secondary education sector and society as a whole. The incentive of sole ownership is an important motivator for students. Ownership rights allow students to seek out partnerships with the private sector in order to bring their IP to market. Improving IP protection for students must be seen as a means in which to create more entrepreneurs and innovative Canadians.

CASA proposes that government adopt a framework for the protection of student intellectual property rights. This framework would serve as set of criteria by which to assess the commitment of institutions to the intellectual property rights of students.

[1] Crago, Martha, Universities Require Transparent Intellectual Property Guidelines, University Affairs, March 2016, Accessed Online: http://www.universityaffairs.ca/opinion/from-the-admin-chair/universities-require-transparent-intellectual-property-guidelines/

Credit: The Canadian Alliance of Student Associations

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Flexible and responsive regulation can lead to enhanced motor vehicle safety (Advanced Lighting Systems)

Question:How can regulations be designed to promote innovation across key sectors?
on 09/12/2016 1473717032
Motor Vehicle Safety Regulations in Canada play a key role in ensuring the safety of operators as well as other occupants and road users and for the m .... Read more

Motor Vehicle Safety Regulations in Canada play a key role in ensuring the safety of operators as well as other occupants and road users and for the most part we have been well-served by aligning the majority of our regulations with the US regulatory standards. However, on occasion there is a rare opportunity to move the road safety performance stick significantly by allowing compliance with higher-performing standards from other, highly respected jurisdictions.  The recent proposed changes to CMVSS 108 would provide flexibility in terms of regulatory compliance options, allowing Advanced Front-lighting systems with Adaptive Driving Beam capability - currently compliant with UNECE regulations.  Such automatic, steerable lighting systems have been in use in Europe and other advanced jurisdicitions for several years and offer significant benefits for increased illumination under a high variety of weather conditions and driving environments both rural and urban.  Adopting these technologies, already proven elsewhere, through a more flexible regulatory approach provides Canada an opportunity to provide leadership in North American motor vehicle safety regulation.  ISED should work with Transport Canada to develop the regulatory framework mechanisms - particularly regulatory compliance flexibility - that can enhance both product safety as well as opportunities for automotive businesses in Canada.

Credit: Greg Overwater; David Adams

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Competition and Foreign Investment Foster Innovation

Question:How can regulations be designed to promote innovation across key sectors?
on 09/09/2016 1473441027
The Competition Law Section of the Canadian Bar Association (the CBA Section) commends the government on its Innovation Agenda and appreciates the opp .... Read more

The Competition Law Section of the Canadian Bar Association (the CBA Section) commends the government on its Innovation Agenda and appreciates the opportunity to offer preliminary comments.

“The ability of nations to commercialize ideas, attract investment, and serve as a test bed for new unproven technologies is underpinned by a regulatory framework that is credible, reliable and forward-looking.” (Canada: A Nation of Innovators, June 2016)

Insofar as regulations may be necessary, the CBA Section agrees with this statement.

Typically regulations are not designed to promote innovation and competition. In contrast, laws of general application in Canada, like those embodied in the Competition Act, can be relied on to promote competitive intensity and efficiency, while protecting consumers and the public.

Competitive intensity fosters innovation. It follows that making it easier to do business in Canada, as well as encouraging domestic and foreign investment, will also support innovation.

In promoting the ability of the Canadian economy to foster innovation, sector-specific regulation may result in allocative inefficiencies by driving investment in certain sectors while potentially, incorrectly, discouraging investment in others. In addition, given the very nature of the regulatory process, any regulation imposed could potentially be dated by the time it is implemented. To remain forward-looking, the CBA Section recommends that regulations be reviewed periodically with a view to understanding their impact on innovation, and that unnecessary or outdated regulations be amended or removed. Even with regular review, however, a regulatory approach does not always have the flexibility to quickly adapt to changing market conditions or opportunities. Regulation has a bias to slow or stifle innovation, not allowing innovators to speedily take advantage of new opportunities as they present themselves.

Policy should favour open markets, which promote increased competition (and consequently increased innovation). As noted, the Competition Act can be depended on to protect the public while promoting competition and efficiency, and consequently innovation. Canada is fortunate that its competition laws are modern and reflect current economic theory, and are harmonious with our major trading partners.

Where choices are made to regulate or restrict markets in whole or part from some aspects of competition, the policy reasons for doing so must be clear and pressing. There would need to be an explicit acknowledgement that regulation will likely result in less competitive markets, and therefore a less vigorous and innovative Canadian economy. To the extent new regulatory measures are contemplated, if possible they should be designed in a manner that does not impede the ability of market participants to capitalize on innovation-enhancing opportunities. It is essential that any regulatory framework be administered in a way that is both transparent and predictable for all market participants.

Credit: Competition Law Section, Canadian Bar Association

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Update building codes and standards to incorporate consideration of the carbon footprint

Question:How can regulations be designed to promote innovation across key sectors?
on 09/08/2016 1473362529
Current building codes are a barrier to lowering the carbon footprint of the built environment. Updating building codes to recognize the growing capab .... Read more

Current building codes are a barrier to lowering the carbon footprint of the built environment. Updating building codes to recognize the growing capabilities of mass timber, engineered wood products and other wood-based building materials in modern building design and construction will reduce emissions. Expanding the height limit of wood structures from four to six stories was a positive step but taller wood buildings—such as the 18-storey residence building at the University of British Columbia and a 13-storey timber tower in Quebec City—have a lower carbon footprint than competing construction materials such as energy-consuming concrete and steel and should be encouraged more. It’s a win-win for both the economy and the environment.

Credit: Forest Products Association of Canada

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Canada can be a global leader in principle-based regulation

Question:How can regulations be designed to promote innovation across key sectors?
on 09/07/2016 1473275076
Tags:
It’s easier than ever for a Canadian entrepreneur to go from a start-up in a garage to a “micro-multinational” with global reach. I .... Read more

It’s easier than ever for a Canadian entrepreneur to go from a start-up in a garage to a “micro-multinational” with global reach.

It used to be the case that reaching a global market required a huge upfront cost: capital investments in computers and manufacturing technology; staffing for human resources, finance, product design, logistics and marketing processes; investments in physical facilities; and expertise to navigate global logistics networks. Today, you can design and manufacture a product using flexible manufacturing facilities, launch a website, implement a marketing plan, contract with a drop shipping service and scale up gradually as consumers discover your business.

Unfortunately, decades of policy making activities have built up a complex web of regulatory hurdles that an entrepreneur must overcome. These hurdles are particularly hard for smaller and new businesses because they lack the resources to navigate compliance requirements established in response to older business models.

As well, regulatory obligations sometimes reflect past attempts to restrict access to a market, whether to protect market incumbents or to encourage the growth of domestic competitors in an industry or service.

The Internet, by contrast, has operated relatively free of government intervention, and the resulting innovation has created enormous benefits for individuals, economies and society.

Policy makers need to be mindful of hurdles placed in front of entrepreneurs and be conscious to trim away regulatory barriers that create obstacles for tomorrow’s job creators.

A simple expression of this impulse is the effort to restrict the flow of data across borders by creating data retention obligations based on territorial borders or the use of domestic data storage facilities.

The challenge faced by regulators was best expressed by Competition Commissioner John Pecman in a speech earlier this year:

It is the duty of policymakers, regulators and enforcers to nurture innovation and keep pace with changing times. That means ensuring regulatory frameworks achieve policy goals while allowing competition and innovation to flourish. And that means using up‑to‑date analytical tools to accurately capture competition dynamics in all industries, especially those undergoing rapid transformation.” (Emerging Issues: Keeping Pace in a Changing World)

Canada, in fact, can help lay down a path for regulators elsewhere to follow. Our data protection legislation, PIPEDA, was created as a careful balance between the need to protect the privacy of Canadians and encouraging the development of new technologies and services. When our Privacy Commissioner investigates a complaint about online services - from Ashley Madison, WhatsApp, Facebook to even Google - the companies listen, identify areas for correction and improvement and make those changes.

Our Copyright Act achieves a careful balance between supporting creators through robust protections while fostering public access to creative works via exceptions, and promotes innovation by limiting the liability of intermediaries for actions of their users.  

Canada, as a member of a number of multinational political and trade organizations spanning the globe, can be an advocate for this sort of flexible, principle-based regulation around the world.

As governments and regulatory bodies elsewhere look to create barriers to international competition, Canada can advocate for international regulatory regimes that encourages innovation, welcome competition, and establish common regulatory principles that safeguard consumer interest while enabling the growth of domestic businesses.

Credit: Sam Sebastian, Managing Director, Google Canada; Steve Woods, Engineering Director, Google Canada

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Agricultural Institute of Canada

Question:How can regulations be designed to promote innovation across key sectors?
on 09/06/2016 1473190793
Tags:
“Early-adopters” of innovation may generate new leadership at the user-level to advocate for greater adoption of new technologies. Incenti .... Read more

“Early-adopters” of innovation may generate new leadership at the user-level to advocate for greater adoption of new technologies. Incentives for this group – from profit-sharing mechanisms to risk management compensation – could be used as incentive to promote the adoption of innovation and the success of innovative Canadian businesses.

A new innovation ecosystem also requires a new model of knowledge transfer that is based on information exchange, participation and co-learning between stakeholders, rather than a simple transfer of data. This new model would benefit research end-users, promote greater collaboration and facilitate the development of participatory research teams which take advantage of a variety of resources and skills to deliver innovation to the market place.

Successful partnerships are mutually beneficial not only to funding partners, but also non-funding stakeholders such as research end-users and consumers. A strong program of interdisciplinary and cross-sectoral partnerships must engage non-funding stakeholders to promote crucial public support for public and private investment in research. Similarly, international research partnerships must have a place for input by non-funding stakeholders like local farmers and indigenous peoples.

Credit: Agricultural Institute of Canada

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An efficient and sustainable health care system through increased policy emphasis on self care and consumer access to consumer health products

Question:How can regulations be designed to promote innovation across key sectors?
on 09/06/2016 1473185874
The proposed Consumer Health Products Framework (the Framework) is a huge step toward a consistent, evidence-based approach to regulating the produc .... Read more
  • The proposed Consumer Health Products Framework (the Framework) is a huge step toward a consistent, evidence-based approach to regulating the products used daily by millions of Canadians in the practice of self-care.
  • The F/P/T overlap in regulating conditions/place of sale creates delays in consumer access to new products, which is compounded by delays imposed by international obligations, and adds layers of complexity and costs for industry,
  • Separating the product approval and conditions of sale decision-making processes, makes it both more difficult for regulators and more onerous for industry.
  • Consumer Health Products Canada (CHP Canada) is seeking federal leadership under the consultations on the Framework, to integrate drug scheduling with the federal consumer health product approval process.
Credit: Consumer Health Products Canada

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Strengthen Canada's IP Framework

Question:How can regulations be designed to promote innovation across key sectors?
on 09/06/2016 1473166659
Robust and well-enforced intellectual property (IP) laws are critical to advancing a global innovation economy. Strong IP laws provide the foundation .... Read more

Robust and well-enforced intellectual property (IP) laws are critical to advancing a global innovation economy. Strong IP laws provide the foundation for the growth of knowledge-based economies, which provide an attractive, rules-based environment for global investors and fertile ground for domestic innovators. The U.S. Chamber’s International IP Index (“Index”), which benchmarks the IP environment in 38 global economies, includes a set of empirical statistical correlations which demonstrate the strong relationship between the strength of an IP environment and important socioeconomic indicators. Specifically, the Index revealed a strong, positive relationship between robust IP protections and increased innovative output, access to venture capital, and foreign direct investment attractiveness. A dynamic IP framework will be critical to maintaining and growing Canada’s global economic competitiveness.

Recognizing the importance of IP protection to fostering innovation, the Canadian government has recently taken steps to improve its IP framework. Specifically, Bill C-8 recently introduced ex officio authority for customs officials, which will strengthen Canada’s enforcement environment by enabling customs officers to seek and detain shipments suspected of containing counterfeit goods. Additionally, the life sciences IP protections included in the recently concluded Comprehensive Economic and Trade Agreement (CETA) – including an effective right of appeal for patent holders and a two year period of patent term restoration – will improve protections for biopharmaceutical companies operating in Canada.

Yet, challenges remain which will undermine the growth of innovative industry in Canada. The Index found that Canada ranked 15th out of the 38 economies benchmarked in the report, lagging become its high-income peers. Specifically, the application of the heightened patent utility requirement is one of the primary ways Canada’s IP system is ripe for improvement in order to bring Canada’s IP framework in line with other developed economies. Since the mid 2000’s, the Canadian Judiciary has implemented a heightened standard for patent utility, which requires that innovators demonstrate the effectiveness of a pharmaceutical at the time of application but raises uncertainty as to how much information needs to be disclosed in patent applications. Companies seeking to invest in new markets need legal certainty that their innovations will be protected, and the continued application of the patent utility standard creates tremendous ambiguity for the pharmaceutical sector as to the validity of their IP rights. In order to create a system which fosters innovative growth across all key sectors, the Canadian government should ensure that its patentability requirements are in line with other developed nations and Canada’s international treaty obligations.

For more information about the Index, please use this link: http://www.uschamber.com/ipindex

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Too many regulations

Question:How can regulations be designed to promote innovation across key sectors?
on 09/02/2016 1472838573
Tags:
There needs to be less regulations for emerging markets and technologies. When there is a new technology, the government is afraid of the unknown and .... Read more

There needs to be less regulations for emerging markets and technologies. When there is a new technology, the government is afraid of the unknown and introduces to many regulations and it slows down development and innovation. The government should let the new industries grow until it becomes somewhat established and can then introduce regulations. 

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Communication and Coordination

Question:How can regulations be designed to promote innovation across key sectors?
on 09/02/2016 1472837102
Tags:
Communication and coordination between cities, provinces and the federal government is not very good. There's a lot of duplication and nobody is coord .... Read more

Communication and coordination between cities, provinces and the federal government is not very good. There's a lot of duplication and nobody is coordinating. There should be more coordination. 

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Harmonize standards across Canada

Question:How can regulations be designed to promote innovation across key sectors?
on 09/02/2016 1472831007
To make it easier for businesses to operate, win government contracts, simply do business in Canada and export out of Canada harmonize the standards o .... Read more

To make it easier for businesses to operate, win government contracts, simply do business in Canada and export out of Canada harmonize the standards or rules for Employment, Transportation, the Environment, Healthcare, and so on.

Establish local and regional administration offices across the country. 

Not only will this help businesses to operate more efficiently and effectively but it will also save billions of dollars in federal and provincial expenditures.

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Level the playing field for the 3rd sector

Question:How can regulations be designed to promote innovation across key sectors?
on 09/01/2016 1472766993
Open up eligibility for nonprofits to Government programs designed to support innovation, research and development e.g. SRHED credits should be avai .... Read more
  1. Open up eligibility for nonprofits to Government programs designed to support innovation, research and development e.g. SRHED credits should be available to nonprofits.
  2. Review and update CRA rules for both nonprofits and charities to creating an enabling framework for nonprofit social enterprise to thrive.
  3. Encourage financial asset managers to support shares in public companies that put prosperity, people and planet first. Make stewardship of the environment, and economic prosperity part of their fiduciary duty.
  4. Ensure that all government funding for research adheres to an open and creative commons license e.g. SSHRC funding should require that all outcomes are made publicly available in order that a range of actors can create opportunities from this publicly funded research.
Credit: @csiTO

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Clean out the cobwebs from 150 years of federal bureaucratic management of Canadian businesses

Question:How can regulations be designed to promote innovation across key sectors?
on 08/30/2016 1472529289
When I read the description of the "ease of doing business" action area, the following words jumped out at me: "To enhance ...marketplace regulations .... Read more

When I read the description of the "ease of doing business" action area, the following words jumped out at me:

"To enhance ...marketplace regulations and standards"

"Enhance" means -- in any setting I know -- to increase, to build up, to grow.

Canadian business does not need bigger, increased, and grown central government regulation.  Government is too often in the way.  Regulation spawned by "big thinkers" who think they see the big picture but cannot fathom the realities of day to day life in the business world seem immune to the idea that more and more regulation actually stifles business and innovation.  It cannot do otherwise.  Every hiker knows that you cannot make your backpack lighter by adding things to it.

My idea is very simple, and it's not new.  It is plain and simple common sense.  But if experience with governments and bureaucracies is at all informative, it will simply be laughed off.

I'm asking for legislation -- or at minimum a government commitment, backed up by actual accountability, to reduce the burden of regulation on business.  Not to DEregulate, only to strip away the molasses of mindless bureaucratic stickum that is holding back our business entrepreneurs, creators and wealth creators.

The commitment should be very simple and verifiable.  Yes, improving and simplifying the tax code for businesses would help, but I think a simpler solution is simply to place an absolute limit on the physical size of the totality of Federal business regulations.  And that limit should be no larger than that which already exists.

Let us suppose one gathers the totality of all federal regulations, forms and so on that are mandated of business through legislation or other legal means, into a single pile of paper in 12 pt font it will come to a certain stack of papers.  Let us suppose, conservatively estimating, that this comes to 50,000 pages.  Then that is the limit.

How does the government make laws in such an environment?  It should be obvious.  In order to CREATE a new regulation, the government must simultaneously, or previously, RETIRE some old regulation.  This way you can clean out that old crud in the books that is dragging business down at the same time as enhancing with new, up to date regulations that suit the needs of the day.  If times are a-changin', then it should make sense that regulations be retired as frequently as they are created.  How about a commitment to doing so?  One that is measurable.

Actually it would be good to see a commitment to retiring sufficiently many old regulations that the totality of business regulation would diminish over time.  You know -- set targets, and deadlines to meet them.  If that pile is 50,000 pages high today, when can the government commit to decreasing it to 49,000?  What's a reasonable timeline to achieving 45,000?  What is a good longterm goal?  25,000?

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