OFA provided comments on the proposal to update regulations under the Farm Registration and Farm Organizations Funding Act. OFA supported the intent and direction of the proposed regulatory approaches and encouraged the Ministry to consider taking further steps to enhance the Farm Business Registration program experience for Ontario farmers and improve the farm organization accreditation process.
Farm Business Registration program:
OFA fully supports the Ministry’s proposal to reduce the amount of unnecessary information collected from farmers. Given concerns with the government’s disclosure of FBR information, OFA recommended limiting the scope of the suggested prescribed FBR information uses. OFA fully supports the Ministry’s proposal to assist Returning Registrants who have experienced a drop in their farm operation’s gross farm income due to the COVID-19 by temporarily modifying how the farm income requirement would be determined for the 2021 program year. Instead of a temporary change, OFA recommended modifying O. Reg. 723/93, s. 1(2) such that the Ministry shall determine the annual gross income of a farming business based on the higher gross farm income amount reported for the most recent taxation year or the taxation year immediately preceding the most recent taxation year if reported. In addition to allowing a New Registrant to obtain an FBR number at any point during the year, OFA recommended modifying O. Reg. 723/93, s. 1(2) such that the Ministry shall determine in the same manner as the gross income from farming of the farming business is determined under the Income Tax Act (Canada) the annual gross income of a farming business that has not filed a tax return for the most recent taxation year or the taxation year immediately preceding the most recent taxation year in relation to the farming business based on documentation confirming the gross farm income of the farming business will be at least $7,000 during the current taxation year.
Farm Organization Accreditation Process:
OFA recommended adding “and has met in the last twelve months” to wording currently found in section 5(2) of O. Reg. 723/93 to state that a farm organization qualifies for accreditation renewal if it meets and has met in the last twelve months the accreditation criteria. OFA recommended that the Minister have sole discretion to temporarily suspend some reaccreditation eligibility requirements and that the Minister’s authority not be contingent upon an emergent situation arising. OFA favoured lengthening the current 3-year accreditation renewal period, provided that farm organizations are not burdened by having to provide additional evidence to the Tribunal on application for renewal of accreditation due to the lengthen period between hearings. OFA believes a 5-year accreditation renewal period is appropriate. OFA fully supports the Ministry’s proposal of a September 1st expiry date for accreditation or reaccreditation period.