Comment
We appreciate the interest in providing flexibility to address present and potential future
circumstances for housing on-farm workers.
We suggest the province consider the anticipated demand for single-site on-farm worker housing that generate design capacity requirements of up to 50,000 l/day, the spatial requirements that may be required for servicing using standard Building-Code systems, and the potential impacts to agricultural functions of a property and the broader agricultural system where such systems are readily permitted.
A lower threshold may provide appropriate flexibility for the majority of cases, while reducing potential for adverse impacts of large-scale outliers who could pursue an approval under the OWRA.
We also note that other rural land uses with large land areas such as golf courses and campgrounds could benefit from an approach wherein distributed wastewater treatment systems with large separation distances could be eligible for approval under the Ontario Building Code.
Submitted November 6, 2025 2:21 PM
Comment on
Proposal to amend the Ontario Water Resources Act to enable the regulation of additional sewage systems under the Building Code to support construction of on-farm worker housing
ERO number
025-0900
Comment ID
169365
Commenting on behalf of
Comment status