September 3, 2013

The Honourable Chris Alexander, PC, MP
Minister of Citizenship and Immigrationa
Office of the Minister
365 Laurier Avenue West
Ottawa, Ontario
K1A 1L1

Dear Minister:

The Canadian Restaurant and Foodservices Association (CRFA) has worked closely with government, to ensure the Temporary Foreign Workers program remains a credible program, as it is of crucial importance to many of our members in areas of the country experiencing labour shortages.

Recent changes to the LMO application process have brought to our attention an exemption in the Immigration and Refugee Protection Act (IRPA) and Regulations that our industry and members consider highly unjust. The Regulations require a foreign-based band or theatrical group to obtain a work permit – only – if they perform in a bar or restaurant.

A similar work permit is not required of foreign artists to perform in a number of other settings before a live audience, performances held in both the public domain and at private events.

We understand bar and restaurant performances work permits are required because these situations may create potential negative labour market prospects for Canadian performing artists.

With respect, CRFA fails to understand the logic that only Canadian restaurant and bar owners would prefer to employ American or other foreign artists over similarly talented Canadian performers. Meanwhile, and highly unfairly, much larger venues such as concert halls are not placed under the burdensome hiring restriction placed on our members. Again, we fail to understand the logic of the regulation, or its selective and preferential application.

In addition, the previous LMO process aided Canadian independent artists by providing opportunities for greater exposure by performing as the warm up act for many well-known foreign bands. The new LMO work permit requirements will result in less opportunities for emerging performers and bands.

We would ask that the unfair application of the work permit regulation be lifted, and cease to be applicable to bar and restaurant performances.

Yours sincerely,
joycereynolds_signature

Joyce Reynolds
Executive Vice President, Government Affairs

September 3, 2013

The Honourable Jason Kenney, PC, MP
Minister of Employment and Social Development
Office of the Minister
Place du Portage, Phase IV, 14th Floor
140 Promenade du Portage
Gatineau, Quebec
K1A 0J9

Dear Minister:

As you are aware, the Canadian Restaurant and Foodservices Association (CRFA) has worked closely with government to ensure the Temporary Foreign Workers program remains a credible program, as it is of crucial importance to many of our members in areas of the country experiencing labour shortages.

Recent changes to the LMO application process have brought to our attention an exemption in the Immigration and Refugee Protection Act (IRPA) and Regulations that our industry and members consider highly unjust. The Regulations require a foreign-based band or theatrical group to obtain a work permit – only – if they perform in a bar or restaurant.

A similar work permit is not required of foreign artists to perform in a number of other settings before a live audience, performances held in both the public domain and at private events. We have written the Hon. Chris Alexander, Minister of Citizenship and Immigration to request an amendment to the unfair application of the work permit regulation.

In the meantime we request that you allow the LMO applications for foreign performing bands or groups to be bundled. The LMO applications will be accepted or rejected for the band and crew collectively making the $275 per person fee unjustifiably high (for example it wouldn’t make sense that the application for the vocalist in the band would be approved but the application for the lead guitar player rejected). Otherwise, it will become cost prohibitive for restaurants or clubs to bring in foreign performers depriving Canadian talent of exposure opportunities. Canadian artists often perform as the warm up act for better known bands.

Thank you for considering our request to make adjustments to the LMO fee structure.

Yours sincerely,
joycereynolds_signature
Joyce Reynolds
Executive Vice President, Government Affairs

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