In a letter to federal Employment Minister Jason Kenney, the board says it's concerned with how the government decides which businesses qualify for the program.
The board says applicants in economic regions with an unemployment rate of six per cent or higher can be denied access to the program.
It says the government considers some communities to be located in regions with an overall unemployment rate of six per cent or higher, though their individual jobless rates are lower.
The federal government overhauled the program in June to ensure Canadians are first in line for jobs and making it more difficult for employers to hire temporary foreign workers.
Kenney has said he'd consider local exemptions in certain areas with very low levels of unemployment.