December 22, 2025 To:…

December 22, 2025
To: Environmental Registry of Ontario
From: Ontario Agri Business Association
Re: ERO 025-1257 – Proposed Boundaries for the Regional Consolidation of Ontario’s Conservation Authorities

Please find enclosed the Ontario Agri Business Association’s submission for the Province of Ontario’s ERO Posting 025-1257.

The Ontario Agri Business Association (OABA) is the provincial trade association representing crop input centres, country and terminal grain elevators, livestock feed mills, and allied agri-businesses. OABA members operate from approximately 500 locations across Ontario and collectively represent more than $23 billion in annual sales.

Ontario’s agri-business sector operates on a province-wide basis with member companies business operations routinely spanning multiple municipalities, watersheds, and conservation authority boundaries. As a result, our members place a high priority on clear, predictable, and consistent regulatory frameworks applied uniformly across Ontario, while recognizing the importance of locally informed watershed management plans and strategies. Conservation authorities play a critical role in natural hazard management, water resource protection, and the delivery of regulatory and environmental stewardship programs that directly influence agricultural productivity, infrastructure investment, and long-term business planning.

OABA supports the Government of Ontario’s direction to consolidate conservation authorities into regional bodies. We recognize that consolidation presents a significant opportunity to modernize governance, reduce duplication, improve coordination, and deliver greater province-wide consistency in policy interpretation and service delivery. From an agri-business perspective, a more standardized and predictable system will reduce regulatory uncertainty, lower compliance costs, and support a competitive and resilient agri-food sector across Ontario.

The success of consolidation, however, will depend on its implementation. Key considerations include the following:
1. Reducing variability between conservation authorities as a core outcome of consolidation
Agri businesses currently experience significant differences in permitting requirements, timelines, technical standards, and interpretation of natural hazard and regulated activity policies among conservation authorities and more specifically experience regulatory oversteps with certain source water protection committees (re: Lower Trent Source Water Protection Committee). These inconsistencies create inefficiencies, frustration and uncertainty, particularly for businesses operating in multiple regions. This variability has been especially challenging for the sector in the context of source water protection planning and implementation that are interpreted different throughout the province. Consolidation should be used to establish harmonized permitting processes, standardized guidance, policy directives and clear province-wide service standards that deliver consistent outcomes regardless of location.
2. Balancing standardization with local and watershed-specific expertise
While standardization is essential, it must be paired with the retention of local and watershed-level technical expertise. Agricultural production varies widely across Ontario due to differences in soils, drainage infrastructure, cropping systems, and climate conditions. Regional conservation authorities should maintain strong sub-regional or watershed-based technical capacity, working closely with agri-businesses and producer organizations to ensure consistent policies are applied with appropriate local context and a practical understanding of on-farm and market realities.
3. Embedding meaningful agricultural sector representation in governance
Meaningful agricultural sector representation must be formally embedded within the governance of consolidated conservation authorities. Agriculture is the predominant land use in many watersheds, and farmers and agri businesses are both regulated entities and frontline environmental stewards. To support effective, practical, and balanced decision-making, agricultural representation must be structured in a clear, consistent, and equitable manner across all regions under the proposed new model.
From an agri-business perspective, this representation could be achieved through a combination of the following mechanisms:
• Designated agricultural representation on conservation authority boards and provincial governance structures, either through provincially appointed seats informed by recommendations from industry and grower associations, or through defined appointment criteria within the provincial posting processes, ensuring the agriculture sector is directly represented in governance and strategic decision-making.
• Regional or watershed-level Agricultural Advisory Committees, comprised of producers, agri-business representatives, and technical experts, to provide practical input on policy application, permitting impacts, and program delivery.
• Formal agricultural representation on Source Water Protection Committees (SWPCs) at a ratio of no less than 20 percent, ensuring source protection planning reflects on-farm and agri-business realities while continuing to meet drinking water protection objectives.
• Clear, province-wide guidance on agricultural engagement, ensuring all consolidated conservation authorities adopt a consistent approach to consultation and collaboration with the agricultural sector.
Embedding agricultural representation through formal governance and advisory structures, rather than relying solely on informal consultation will improve transparency, consistency, and stakeholder confidence in the consolidated system.
4. Maintaining fully functioning Source Water Protection Committees
Fully functioning Source Water Protection Committees must be maintained within any consolidated conservation authority structure. Source water protection planning is essential to safeguarding drinking water supplies while enabling continued agricultural activity. Consolidation should enable these committees to ensure clear mandates, consistent policy application across regions, and meaningful, equitable stakeholder representation, including agriculture.
5. Ensuring consistent, reliable, and timely service delivery
Consolidation must result in consistent, reliable, and timely service delivery, particularly with respect to permitting and approvals. Agri businesses rely on predictable timelines to support infrastructure development and operational improvements. OABA recommends that the province establish province-wide performance benchmarks for permit processing times, access to technical staff, and client communication, supported by transparent reporting and accountability.
6. Maintaining and strengthening stewardship and technical programs
Conservation authorities deliver important stewardship and technical programs supporting soil health, erosion control, 4R nutrient management, and water quality improvements on agricultural lands. Consolidation offers an opportunity to improve program availability, sharing of information and consistent delivery across Ontario, while preserving the local relationships and trust that are essential for effective farmer participation and agri business engagement.

In conclusion, OABA supports the consolidation of Ontario’s conservation authorities as a means to improve coordination, reduce variability, and enhance province-wide consistency while reducing the level of frustration experienced within the sector associated with inconsistent policy and delivery timelines. To be successful, consolidation must preserve local expertise, maintain strong source water protection governance, and include clearly structured, province-wide agricultural sector representation in both governance and advisory processes. These elements are essential to delivering practical, predictable outcomes that support the long-term sustainability and competitiveness of Ontario’s agri-food sector.

Thank you for the opportunity to provide input on this proposal. OABA would welcome continued engagement as the government advances this important initiative.
Respectfully,

Russel Hurst Executive Director, OABA
E: russel@oaba.on.ca