As at August 2004

Solicited Submissions

Provided in those situations where an official response to legislative changes or proposed new legislation has been requested.

1. Advise the OBA of the proposed written submission.  The OBA may be able to assist you with many aspects of the submission.
2. Prior to review by the OBA, the written submission should be approved by the members of the Section (either by general circulation to the members or at a general Section meeting), or if not possible, as a result of the number of members or where there is an insufficient period of time, (at least) by members of the Section Executive.
3. After approval by the Section the proposed submission should be forwarded to the OBA in hard copy and in electronic format.  The submission will first be reviewed by the Submission Review Committee in order to determine if the submission has been drafted in accordance with this policy and the standard submission layout.  The Chair of the Submission Review Committee will circulate the proposed submission to the Submission Review Committee members for their comments.  Where there are questions or comments, the Chair or Director may contact (one of) the author(s) to discuss.
4. At least one of the authors (if necessary) should be available to attend the OBA Executive Committee meeting to speak to the submission. If it is timely, the Executive will make a recommendation that the submission be reviewed by the OBA Council.
5. At least one of the authors should again be available to attend the Council meeting to speak to the submission.  This step is not always used, as Council meets only four times each year.
6. In either case, the OBA will be responsible for formatting the submission and forwarding the submission to the appropriate organization or government. It will be sent out on OBA letterhead, accompanied by a letter from the President or Executive Director stating that it represents the views of the Association.  The submission is also recorded in the OBA Submission Index and in the Archival Records permanently.

 

Unsolicited Submissions

Provided in those situations where the submission is not being made in response to an official request for comments.

In order to provide a higher level of autonomy and to expedite the process, the OBA is aware that there may be circumstances where a Section determines that it is appropriate to make a submission with respect to a matter where there has been no request for submissions.  In those cases, the OBA has determined that unless the specifically Section requests, the OBA need not be involved with the presentation of the submission.

Each Section will have (access to) Section specific OBA letterhead with which to use for submissions.  While it will not be necessary to seek the approval of or follow the review process of the OBA in these circumstances, the Section should nevertheless follow the procedure set out below.

1. The written submission should be approved by the members of the Section (either by general circulation or at a general Section meeting) or if not possible or doable by, members of the Section Executive.
2. A review the draft submission should be undertaken in order to determine if the submission is in accordance with the standard submission layout.
3. After making the submission, the Section should provide a hard copy and electronic copy of the submission to the Director for the OBA’s records.

Time Sensitive Submissions

To address circumstances where there are submissions required on a time sensitive matter.

Advise the OBA of the proposed written submission.

Standard Submission Layout

1. As a general rule, and in order to establish a minimum level of consistency in the quality of submissions, it is suggested that the submission follow the general layout format:

   Table of contents (where appropriate);
   Executive summary;
   Background
   Issues/Argument/Recommendations;
   Conclusions;
   List of authors

2. When going through the process of drafting the submission (and prior to) the following points should be followed so that the submission will be established as a standard format. The Submission Review Committee will consider these matters when the paper is being reviewed.

• Whether there are any other Sections within the OBA that might be affected by these opinions and if so, whether those Sections have been made aware of this submission and consideration given to the most appropriate mechanism for affording the other Section(s) an opportunity to comment as well.
• Whether there is a minority view within the Section on the issue(s) being considered and whether those views have been included in the submission.
• Whether the submission is consistent or compatible with existing policy expressions made by OBA.
• Whether the submission is consistent with OBA’s visual identity policy.
• Whether the submission express its message in a language and form that will be understood by the audience targeted.
• Whether the submission supplies adequate background information and stated purpose for the submission.
• Whether the submission is well supported by facts and law.
• Whether the submission is sufficiently explicit so as to stand on its own.
• Whether the tone of the submission is appropriate, whether the submission avoids a defensive or antagonistic approach so that it may have long-term independent relevance and will not embarrass OBA.

Administration

Louise Harris, Director of Advocacy, Government Relations & Communications is also an excellent resource for any questions that you may have. Call her at (416) 869-1047 or 1-800-668-8900 ext. 317 or reach her by e-mail at lharris@oba.org