OFA comments on the proposed changes to the permit-by-rule framework. OFA is in favour the of the intent of creating more efficient environmental permissions processes.

• OFA supports exploring the option of having assessments subject to peer review through a third-party consultant.
• When establishing discharge criteria, OFA believes the potential impact to agricultural properties must be considered.
• The timely rehabilitation of aggregate operations to sustainable agricultural production must remain.
• The development of codes of practice outside of the legislation is acceptable. However, OFA believes that this cannot occur without developing very strong enforcement protocols.
• OFA strongly supports the unmentioned benefit of moving certain activities to an EASR – that is a faster processing time for those activities that remain subject to more traditional permissions such as Environmental Compliance Approvals (ECA) and Permits-to-Take-Water (PTTW).

OFA looks forward to further conversations and consultations regarding this process, as well as exploring options for some agricultural processes to be brought under the EASR process.