These exorbitant increases in financial burdens will be felt at a time when agricultural permittees are already being forced to shoulder additional regulatory burdens and associated market pressures that threaten the underlying financial viability of farms.
Please read our full, submitted comments here:
Key Highlights:
Impact on Family Farms: OFB expresses significant concern over the proposed fee increases for Removal-Fill and Wetland Delineation Permits, emphasizing the financial burden on family farms and ranches. Over 2,000 farms were lost between 2017 and 2022, with regulatory costs contributing to this decline.
Escalating Costs and Administrative Burdens: Permit applications have grown substantially in complexity and cost. A Bandon rancher’s tide gate permit, for instance, increased from 22 pages in 1999 to over 500 pages in 2024, with project costs jumping from $150,000 to $3.5 million.
Fee Increases: The proposed fees would increase dramatically, with conservative estimates suggesting a 634% increase in the first year and an 1,103% increase by year five.
Unfair Fee Classification: Most family farms fall under Tier 4, paying significantly higher fees compared to Type 1 applicants, who qualify for reduced fees.
Inflation Adjustments: The proposal includes a 5% automatic inflation increase, exceeding the Consumer Price Index (CPI) of 2.8%.
Differentiating Agriculture from Development: OFB calls for a streamlined process for agricultural maintenance, distinguishing it from land development activities and advocating for reduced fees for routine maintenance of ditches, dikes, and tide gates.
Concerns About Long-Term Sustainability: The fee increases threaten the financial viability of farms, which play a critical role in environmental stewardship and rural economies.
Recommendations:
Establish simplified, automatic processes for agricultural maintenance.
Maintain lower fees for infrastructure maintenance.
Recognize the distinct nature of agricultural land use compared to development.
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