OFA believes that any Administrative Monetary Penalty (AMP) should be proportional to the risk to the environment caused by the infraction and take into account both risk management due diligence as well as mitigation efforts to lessen any environmental damage. OFA encouraged the continued use of the Ministry of Environment, Conservation and Park’s Informed Judgement Matrix along with case specific considerations for agricultural operations and furthermore that “Compliance Category 1” infractions are not subject to an AMP, due to the lack of risk to the environment. OFA recommended that ordering an AMP should be the decision of the Director. OFA does not support granting Provincial Officers the power to impose an AMP on an agricultural operation. OFA is in favour of the Total Penalty provisions that establish the maximum AMP for each contravention.