Comment
The Wellington Federation of Agriculture (WFA) proudly represents more than 1500 farm family members across Wellington County, supporting our members and the agri-food industry on issues, legislation, and regulations managed by all levels of government. Being that it is the largest farm organization within the County of Wellington, the WFA works to ensure the agri-food sector and rural communities are included, consulted, and considered in new and changing legislation that impacts the sustainability of farm businesses.
The WFA has concerns regarding agricultural representation within the proposed large regional conservation authorities. Wellington County is currently served by multiple conservation authorities, reflecting distinct watersheds, landscapes, and agricultural systems. Under the proposed consolidation model, Wellington County would be incorporated into 3 Regional Authorities (Lake Erie RCA, Huron-Superior RCA and Western Lake Ontario RCA). There are significant concerns that Wellington County’s agricultural interests—particularly those of smaller, rural municipalities—will be diminished or overlooked within such expansive governance structures.
The WFA appreciates the government’s acknowledgement of the concerns raised by Ontario farmers regarding Conservation Authorities (CAs), such as the unpredictable and inconsistent conditions they sometimes create for agricultural operations. We are supportive of the government’s goal to transform the CA system to reduce duplication, free up resources, and better align CA activities with provincial priorities related to housing, infrastructure, the economy, and climate resilience—recognizing that agriculture is a critical contributor to both Ontario’s economy and climate resilience.
That said, the WFA does not share many of the concerns expressed elsewhere in the province. Our experience with Wellington County’s existing conservation authorities has been largely positive, with local CA staff demonstrating strong knowledge, accessibility, and a constructive approach. Their conservation programming and technical expertise have been of clear value to our farm community.
Summary of Key Comments:
Essential Requirements for Conservation Authorities from an Agricultural Perspective
• Consistency and transparency: Farmers continue to experience significant variability in CA policies, standards, processes, service delivery, permit requirements, and fees across Ontario. A more consistent and transparent system is needed to improve fairness, predictability, and efficiency.
• CA Boards of Directors: Governance should reflect land use—not population—and include proportional representation based on Agricultural, Rural, Urban, and First Nations land uses, with at least one agricultural representative. As CA boundaries expand, agricultural representation must also increase to ensure rural municipalities and landowners—who are most affected by CA decisions—have a meaningful voice. We welcome further discussion on board structure and financing.
• Local agricultural knowledge and capacity: Effective CA–farmer relationships rely on staff with both technical expertise and practical understanding of agricultural operations. Revised CA structures must retain and strengthen this expertise to support stewardship, drainage, and farm development while protecting people and property.
• Local conservation programming: Existing local CA programs and staff are very valuable resources for farmers, providing both technical support and financial benefits, and should be maintained. CA programs recognize agriculture as a key land use and economic driver.
Summary of Key Comments:
Essential Requirements for CAs from an Agricultural Perspective:
● Consistency and transparency of policies, standards, processes, services, permit requirements and fees. Farmers continue to experience significant variability in service delivery, policies, processes, and treatment across Ontario, and require a system that would improve fairness, predictability, and efficiency.
● CA Boards of Directors: Consider proportional representation based on land use (Agricultural, Rural, Urban) and includes at least one agricultural representative. As geographic boundaries expand, the number of agricultural representatives must also increase. Because CA jurisdiction is inherently tied to land and water – not population – new governance structures should reflect land-use realities. Ensuring proportional representation based on land use (Agricultural, Rural, Urban and First Nations) with meaningful agricultural involvement, is essential. Proportional representation based on land use could help ensure that smaller, rural municipalities have an appropriate voice that reflects both governance influence and financial impact. Similarly, it is primarily the agricultural and rural landowners who will be impacted by CA decisions, and therefore, they must have a significant voice for decision making. We look forward to participating in future discussions regarding CA Board structure and financing.
● Maintain Local Agricultural Knowledge and Capacity. The strongest relationships between farmers and CAs have developed where CA staff possesses both technical expertise (hydrological modelling, soil management, and erosion control) and an understanding of agricultural operations and practices. This knowledge has supported stewardship initiatives, effective drainage projects, and appropriate farm expansions. Any revised CA structure must retain and continue to build this agricultural expertise, along with a commitment to collaborate with the sector in ways that support its economic contributions while consistently protecting people and property.
● Maintain local conservation programming. Our local conservation authorities have programs and staff that are valuable as a resource to farmers, both from a knowledge standpoint, and from a financial lens.
Boundaries of Regional Conservation Authorities:
Creation of 19 Regional CAs based on the existing Source Protection Regional structure / boundaries. WFA’s prefers maintaining current boundaries (36 CAs) but recognizes that the provincial move towards regional authorities. Aligning with the Source Protection Regional (SPR) structure—creating 19 Regional CAs—makes more sense than the proposed seven Regions. Expansive boundaries risk weakening community relationships, particularly in rural areas, as hydrogeology, soils, landscapes, and agricultural systems vary widely.
Such expansive boundaries will make it challenging to maintain meaningful community relationships, especially in rural communities. Smaller regions ensure that local agricultural needs are understood and reflected in decision-making. Soil types, agricultural sectors (crop, livestock, greenhouse), and stewardship priorities can differ immensely across these areas. Creating 19 Regional CAs based on the Source Protection Regional structure would better preserve a watershed-based approach while offering more geographically coherent boundaries and stronger local accountability than a system of only seven Regions. This approach balances consolidation goals with responsive, locally informed decision-making. Overall, following the SPR structure maintains local representation, responsiveness, and efficiency while ensuring decision-making benefits from local knowledge and meaningful community involvement.
Creation of a Provincial Ontario Conservation Authority (OPCA):
● Agricultural representation on the OPCA Board. It is essential that the OPCA has agricultural representation on its Board of Directors, ideally these positions would be nominated by the agricultural community.
● Ease of permitting system that will not require a consultant for permit applications and assistance from local, knowledgeable CA staff.
● Best Practices. Working with members of the agricultural community to identify best practices that have fostered successful relationships with Cas and provide guidance on how to replicate them in areas that have lacked a constructive relationship.
We thank you for your time and the ability to comment.
Respectfully yours,
Submitted December 22, 2025 11:32 PM
Comment on
Proposed boundaries for the regional consolidation of Ontario’s conservation authorities
ERO number
025-1257
Comment ID
179182
Commenting on behalf of
Comment status