OFA has provided comments to the Environmental Registry of Ontario (ERO) on the two following proposals:
ERO 025-0899: Policy proposal to regulate additional sewage systems under the Building Code to support construction of on-farm worker housing
- The proposed setbacks and clearances make the policy unworkable for most farms and do not resolve inequities between clustered rural properties and agricultural operations.
- The sector recommends applying existing Ontario Building Code (OBC) Class 4 septic system clearance policies to on-farm worker housing.
- Using current OBC Class 4 rules would provide a workable solution while maintaining equal or greater protection for human health, the environment, and neighbouring properties.
- OFA does not believe additional protective measures are necessary.
- OFA supports maintaining the same OBC maintenance requirements used for existing Class 4 septic systems.
ERO 025-0872: Streamlining environmental permissions for sewage works servicing on-farm worker housing
- Requiring the owner to confirm construction compliance is unreasonable when licensed installers and engineering professionals are already responsible for system design and installation.
- While record-keeping is important, requiring an annual report based on those records is excessive.
- Ministry concurrence prior to self-registration must be as fast as possible, given the time-sensitive nature of agriculture and the urgent timelines for on-farm worker housing.
- OFA seeks further discussion on the classification of agricultural wash-water as “sewage.”
- Monitoring requirements must be balanced with the time sensitive operational realities of farming.
- OFA is concerned about the cost and time implications of advanced treatment technologies, especially when passive, conventional systems may adequately protect health and the environment.