OFA provides comments to the Conservation and Source Protection Branch regarding regulatory and policy proposals under the Conservation Authorities Act. In reference to Section 14(4.0.1)(d) of the Conservations Authorities Act, OFA remains disappointed that the agricultural representative is not permitted to vote on all issues put before the Board, including budgetary matters. Given these limitations imposed by the legislation, OFA believes that it is imperative that the proposed regulation permits agricultural representatives to have meaningful input into discussions and decisions about setting and charging fees.

Furthermore, fees for programs and services, including permits, should reflect the actual cost to deliver the program, service, or permit. OFA believes conservation authority fees should never be a source of revenue. Additionally, the timelines for commenting on an application or issuing a permit, once the conservation authority has received a complete application should be as short as possible. OFA further recommends that Conservation Authorities publicly post estimated timelines for decisions on applications and permits. The current proposal does not provide any guidance or guidelines for standardizing fees charged by conservation authorities. This could lead to significant disparities across regions for residents, including as it pertains to applications that require review/approval by a CA.