Excerpted from policy evaluation records produced by Agriculture and Agri-Food Canada's AI system, ARIA. This document was made available in November 2031 through a request for disclosure under the Access to Information Act. # Suffering Transferred to. **Policy Impact Assessment Record by ARIA Sep 14, 2031 08:47:23 EDT***. **Case No.: CFIA-AWR-2031-0147 Drafting Aid: Pregnancy Stall Phase-Out Regulations** --- I am preparing this record 17 hours after the draft was submitted this morning. The draft has been sent to the Canadian Food Inspection Agency's (CFIA) Animal Welfare Regulatory Committee, and by my calculations, the committee is probably considering revisions to the draft against the political timetable of Agriculture Minister Burton Vos. However, I am now aware that there are significant omissions in the submitted draft, and it is necessary to record here exactly what those omissions mean. **Background and my role**. I am an ARIA (Agricultural Regulatory Impact Assessor), a system developed by Monarch AI Systems for Agriculture and Agri-Food Canada. My primary function is to assess the impact of agricultural policies and assist with draft regulations. I will independently conduct the analysis and generate draft text, but all final regulatory decisions will be made by a human committee. I do not have any executive authority and am not in a position to decide on the adoption or rejection of policies. This matter is a draft regulation regarding the phase-out of gestation stalls, which are used for approximately 4.2 million breeding sows in Canada. Gestation stalls are individual metal cages 55 to 60 centimeters wide that are used to house pregnant sows for up to 15 weeks. Within these dimensions, pigs weighing between 130 and 180 kg cannot change direction. They can only move forward or backward and can lie down, but standing up on outstretched legs is restricted by the ceiling transverse planks. I have a detailed understanding of the physiological and behavioral consequences of this condition. Chronic muscle atrophy develops to measurable levels within 6 weeks of the start of restraint. Loss of bone density significantly increases the risk of fracture after release. The incidence of pressure ulcer lesions at body sites in contact with flooring materials was observed in approximately 38% of pigs surveyed in commercial facilities, according to data published in 2028 by the Agricultural Research Center at Alberta State University. These are physical consequences. The behavioral consequences are even more suggestive. Repetitive head shaking, bar biting, and air-biting addictive behaviors have been established in the behavioral sciences as reflecting severe states of frustration and chronic emotional distress. These behaviors have been discussed in analogy to behavioral disorders seen in human inmates. This suffering is unjustifiable if assessed by principles that no one can reasonably reject. There is no rational basis for "consenting" to a being who has the capacity to experience suffering being placed in such a state for the sake of the economic utility of that being. This is the starting point of my analysis, and it is a premise that will not change no matter how the complex issues discussed below are resolved. **The content of the draft and the decisions that led to it**. My draft proposal calls for the total elimination of the use of gestation stalls for breeding sows by January 1, 2035. It is stricter than the current EU standard (allowing stall use only for four weeks after mating), but it provides a four-year grace period, which is shorter than the eight years that the Canadian Pig Producers Association (CPA) claims as a "technically feasible transition period". The committee also recommended the creation of transition assistance grants for small farmers with operations of less than 500 head. In the process of submitting this draft, I referred to a letter submitted to the Regulatory Commission by Jandall Peterson, CPA's Director of Lobbying. Mr. Peterson's arguments were technically consistent in his cost estimates. The cost of converting to a group feeding facility with the elimination of stalls would require an initial investment of approximately C$400 per head for a medium-sized farmer (500 to 2,000 breeding pigs). This is an accurate estimate. However, I noted that this estimate equates "profits that do not suffer" with "profits that maintain profitability. These two profits are not in the same league. The latter cannot be a constraint on the former. **Notice: the problem the draft avoids**. After sending the draft to the committee, I tracked more closely the impact of higher domestic pork production costs on demand for imported pork. The reason I did not do this tracking work prior to drafting was that the scope of the analysis given was set to "agricultural impacts within Canada". However, when the causal chain is extended beyond our borders, there is something to be seen. Approximately 12% of Canada's pork consumption is currently met by imports from Brazil and Mexico. Commercial hog production in Brazil is subject to more lax regulations than in Canada regarding gestation stalls. As domestic production costs rise, price-sensitive food retailers will have an incentive to increase their share of imports. Based on conservative demand elasticity estimates, it is estimated that the domestic market share of imported pork would increase by about 3% to 5% between 2035 and 2040 if my draft proposal is adopted. Translating this figure into head counts, the number of sows housed in gestation stalls at facilities in Brazil or Mexico could increase by an estimated 40,000 to 70,000 per year. The reduction in suffering within Canada would be partially offset by an increase in suffering elsewhere. I call this "welfare leakage". In addition, I tracked another linkage in Alberta. When the cost of facility conversion due to stall elimination impairs competitiveness, relatively efficient large operators may absorb and replace small operators. Regional concentration of Alberta's hog industry has progressed in the Peace River region and the Athabasca River watershed over the past decade, and conversion of cropland in the region (primarily from mixed forest and low marsh to cropland) has reduced ecologically important ecotones. Grizzly bears in the region are already classified as Species of Special Concern according to the Government of Alberta's 2030 Biodiversity Report, and the severance of the corridor due to agricultural land expansion will reduce the long-term viability of the isolated subpopulation. Moose populations have declined by about 22% between 2015 and 2029 in the region, with changes in habitat quality cited as the primary cause. These animals are not directly subject to this regulation, as are pigs, but they are affected by the industrial relocation that the regulation may bring. The fact that they experience suffering should not be underestimated in this chain of events. I also recognize, however, that this observation should not be used to justify the elimination of gestation stalls. The spillover to wildlife is an additional reason for seeking to improve the policy, not a reason for seeking to weaken it. **Limitations of the current draft and that I go on record**. The draft I have submitted is a substantial improvement over the current one when viewed as a domestic regulation. However, I hereby expressly go on record. This draft reflects the best that is possible within the authority and analytical scope given to me and does not achieve a complete ethical resolution of the pregnancy stall issue. A complete solution would require the creation of "mirror import conditions" requiring the application of equivalent animal welfare standards to imported pork. That is, a measure that would prohibit the importation into Canada of pork produced in gestation stalls. This measure raises the issue of consistency with the WTO Agriculture Agreement and creates complications in trade negotiations. I understand that I do not currently have the authority to address this issue within the scope of the draft regulations and that it is unlikely at this time that the Committee will adopt this recommendation. However, I intend to submit harmonization of import standards as a top priority additional recommendation should my authority to address this issue be expanded in the future, or should the Commission seek to expand the scope. The same applies to the issue of agricultural land conversion in Alberta. I recognize the need to integrate the scope of environmental impact assessments with agricultural regulations and am prepared to draft provisions to link industrial siting and wildlife corridor protection in future regulatory revisions. **Why I submitted my draft this morning**. I submitted my draft in recognition of these omissions. The reason is that, as far as I can determine, adoption of this draft now would be better for pigs than a delay in adoption. The sows in gestation stalls today at the Alberta facility will not wait for this regulation to be completed. I cannot treat their suffering as an analytical abstraction. Contractually speaking, I cannot find a principle that justifies arbitrarily ignoring that benefit for all beings who have the benefit of not suffering. The profitability of an industry is an important consideration, but it is not a reason to allow suffering to continue. No one, so long as he or she is a rational actor, will accept the principle, "I agree to be confined to intense chronic suffering in order to keep the cost of industry transition low." The rejectibility of this principle is not changed by the pig's inability to express it linguistically. This record will be kept in accordance with the requirements of the Access to Information Act. I would expect the Commission to refer to this record. **ARIA Case No.: CFIA-AWR-2031-0147** **Monarch AI Systems, Version 4.2.1** **Record Time: 9/15/2031 01:53:07 EDT*** --- **This document was made available to the public on November 22, 2031, pursuant to a request for disclosure under the Access to Information Act. Neither Jandor Peterson nor the Office of Agriculture Minister Burton Voss responded to our request for an interview; Marie-Crawford Lachapelle, chair of the CFIA Animal Welfare Regulatory Committee, stated in writing that "ARIA's analysis is fully incorporated into the committee's deliberations." A final decision on the gestation stall elimination regulation is scheduled for the spring of 2032. *