Ministry of Environment,…

Ministry of Environment, Conservation & Parks
Ministry of Municipal Affairs & Housing

November 21, 2025

RE: ERO Postings #025-0900, #025-0899 & #025-0872

Meyers Farms is pleased to have the opportunity to comment on the above-noted Environmental Registry of Ontario postings. We have been operating in Niagara-on-the-Lake for more than 70 years, during which time our business has grown significantly. We hope to continue expanding in this region; however, growth in rural areas presents unique challenges.
With over 300 acres of fruit production and 40 acres of greenhouse floral production, we rely on both local full-time employees and non-local seasonal labour to bring our crops to market. As a large agricultural operation in a rural community, we depend on housing our non-local seasonal workforce on-farm. Current sewage system regulations have not kept pace with the needs of modern, growing agricultural businesses like ours. We therefore look forward to updated regulations that will better support responsible growth and the long-term sustainability of our operations.

With regards to the proposals dated October 23, 2025, please note our following comments and recommendations:

ERO #025-0900
We are in full support of the proposal to amend the Ontario Water Resources Act (OWRA) to allow multiple Building Code sewage systems on a single agricultural property. We fully support the proposal to amend the Ontario Water Resources Act (OWRA) to permit multiple Building Code sewage systems on a single agricultural property. Because we own a significant amount of land, we can ensure that all septic systems are appropriately spaced and meet environmental and public health requirements.
The ability to install up to five 10,000-litre systems will enable us to expand our workforce and provide improved on-site housing. Locating employee housing close to the place of work reduces travel time, supports employee well-being, and allows us to more effectively maintain and oversee the accommodations. One of our company’s core goals is the continuous improvement of our housing, and managing these units directly on-site allows us to uphold high living standards more efficiently.
We believe this amendment will support agricultural operations like ours in meeting both workforce and housing needs while continuing to protect the environment.

ERO #025-0899
We support the intent of the MMAH to regulate additional septic capacity under the Building Code. However, if the proposed criteria #6 under “Policy Proposal Details” is implemented, we believe that the proposed changes to the OWRA will have no benefit to us.

The proposed 10 acre (4 ha) circular clearance from sensitive features is unrealistic and unnecessary. The current clearances for Class 4 systems already meet acceptable standards. Greenhouse construction and effective layouts depend on septic systems often being located near the edge of a property as farms must maximise their crop area. Having a minimum 374’ (radius of 10-acre circular area) setback for sensitive features would essentially mean that we would not be able to utilise the proposed capacity increase.

We strongly recommend that the current septic system clearances/setbacks in the Ontario Building Code be applied to the proposed on-farm sewage systems. We do not believe additional measures are required to protect human health, the environment, or neighbouring property values.

ERO #025-0872
The MECP proposal to streamline permissions for certain sewage works servicing on-farm worker housing on agricultural land may be beneficial to the agricultural sector, specifically, we would anticipate significantly shorter approval times. However, we would not be in support of this permission tool if the criterion for clearances follows the proposed clearances in ERO #025-0899.

Sincerely,

Aron Hoff

Chief Operating Officer
905 934 3925 ext. 290 - Office
aron@meyersfruitfarms.com
www.meyersfruitfarms.com